Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
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...
Legal services rendered by the partnership were treated as professional services, not fees for technical services; receipts from Indian engagements could not be taxed under section 9(1)(vii), and the related addition was deleted. The Tribunal also held that a UK partnership was fiscally transparent under UK law, so treaty protection under the India-UK DTAA extends only to the extent the income is taxed in the UK as income of a resident. Non-UK resident partners could not invoke the India-UK DTAA merely by being partners in the firm; their taxability had to be examined under the DTAAs of their respective countries of residence. The matter was remanded to the Assessing Officer for that limited examination.
Legal services rendered by the partnership were treated as professional services, not fees for technical services; receipts from Indian engagements could not be taxed under section 9(1)(vii), and the related addition was deleted. The Tribunal also held that a UK partnership was fiscally transparent under UK law, so treaty protection under the India-UK DTAA extends only to the extent the income is taxed in the UK as income of a resident. Non-UK resident partners could not invoke the India-UK DTAA merely by being partners in the firm; their taxability had to be examined under the DTAAs of their respective countries of residence. The matter was remanded to the Assessing Officer for that limited examination.
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