Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
Customs relief for Strait of Hormuz maritime disruptions remains available, with existing conditions continuing unchanged through the extended validit...
GIA India was treated as an independent entity and, on the Tribunal's factual findings accepted by the HC, no fixed place, service or agency PE of GIA US arose in India under Article 5 of the India-US DTAA. On royalty, the Court applied the real income principle and the APA framework to hold that only the royalty ultimately retained by GIA US after refund of the excess amount could be taxed in India under Article 12. The transfer pricing recomputation provisions invoked by the Revenue were held inapplicable because the arm's length price was governed by the APA and the refund had already been reflected in GIA India's tax position.
GIA India was treated as an independent entity and, on the Tribunal's factual findings accepted by the HC, no fixed place, service or agency PE of GIA US arose in India under Article 5 of the India-US DTAA. On royalty, the Court applied the real income principle and the APA framework to hold that only the royalty ultimately retained by GIA US after refund of the excess amount could be taxed in India under Article 12. The transfer pricing recomputation provisions invoked by the Revenue were held inapplicable because the arm's length price was governed by the APA and the refund had already been reflected in GIA India's tax position.
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