Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
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Routine back-office support services were not royalty under the applicable DTAAs because the agreements showed no grant of rights in copyright, patents, designs, secret processes or equipment, and the domestic Act could not override the more beneficial treaty. The same receipts were also treated as business profits and, in the absence of a permanent establishment in India, not taxable in India. Claims against fee for delayed return filing and interest for delayed filing were remanded for verification of whether the returns were filed within time. The challenge to initiation of penalty under the anti-underreporting provision was rejected as premature.
Routine back-office support services were not royalty under the applicable DTAAs because the agreements showed no grant of rights in copyright, patents, designs, secret processes or equipment, and the domestic Act could not override the more beneficial treaty. The same receipts were also treated as business profits and, in the absence of a permanent establishment in India, not taxable in India. Claims against fee for delayed return filing and interest for delayed filing were remanded for verification of whether the returns were filed within time. The challenge to initiation of penalty under the anti-underreporting provision was rejected as premature.
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