Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
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Payments for onsite software development services routed through a US branch were treated as fees for technical services under domestic law, but treaty relief under the India-US DTAA applied because the make available condition was not satisfied, so no tax was deductible and the section 40(a)(i) disallowance failed. Licensed access to website content carrying the foreign supplier's branding was characterised as royalty, so the non-deduction of tax attracted disallowance. The section 14A/Rule 8D addition was deleted for lack of objective satisfaction, CSR donations remained eligible for deduction under section 80G subject to verification, and the Tangent International issue was remanded for examination of the scope of work.
Payments for onsite software development services routed through a US branch were treated as fees for technical services under domestic law, but treaty relief under the India-US DTAA applied because the make available condition was not satisfied, so no tax was deductible and the section 40(a)(i) disallowance failed. Licensed access to website content carrying the foreign supplier's branding was characterised as royalty, so the non-deduction of tax attracted disallowance. The section 14A/Rule 8D addition was deleted for lack of objective satisfaction, CSR donations remained eligible for deduction under section 80G subject to verification, and the Tangent International issue was remanded for examination of the scope of work.
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