Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
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Finance Act 2025 amendment rendered the challenge to the validity of the assessment infructuous. On taxability of receipts under the India-UK DTAA, the Tribunal held that general business support services rendered under a cost contribution agreement were managerial in nature and did not make available technical knowledge, experience, skill or know-how to the Indian recipient; the receipts were therefore not fees for technical services. It also directed recomputation of interest for the relief granted in appeal.
Finance Act 2025 amendment rendered the challenge to the validity of the assessment infructuous. On taxability of receipts under the India-UK DTAA, the Tribunal held that general business support services rendered under a cost contribution agreement were managerial in nature and did not make available technical knowledge, experience, skill or know-how to the Indian recipient; the receipts were therefore not fees for technical services. It also directed recomputation of interest for the relief granted in appeal.
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