Country of Origin Certificates and declared transaction value supported preferential customs exemption where authenticity and invoice prices remained ...
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...
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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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