Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
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Receipts of a German tax resident individual for market support, business development, managerial and consultancy services were treated as independent personal services under Article 14 of the India-Germany DTAA, not fees for technical services under Article 12. The Tribunal held that Article 14 is the specific treaty provision for an individual's independent professional activities and, once its conditions are met, the income cannot be recharacterised under Article 12. As the assessee had no fixed base in India and did not exceed the treaty stay threshold, the receipts were taxable only in Germany. The additions for A.Y. 2018-19 were deleted, and the same treatment was applied for A.Y. 2019-20, subject to verification of the year of receipt for certain payments.
Receipts of a German tax resident individual for market support, business development, managerial and consultancy services were treated as independent personal services under Article 14 of the India-Germany DTAA, not fees for technical services under Article 12. The Tribunal held that Article 14 is the specific treaty provision for an individual's independent professional activities and, once its conditions are met, the income cannot be recharacterised under Article 12. As the assessee had no fixed base in India and did not exceed the treaty stay threshold, the receipts were taxable only in Germany. The additions for A.Y. 2018-19 were deleted, and the same treatment was applied for A.Y. 2019-20, subject to verification of the year of receipt for certain payments.
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