Statutory transfer formalities invalidated alleged share and property transfers, while retrospective record manipulation constituted oppression and mi...
Provisional attachment of laundered funds and equivalent-value property sustained, with statutory protection limited to pension, gratuity and providen...
Insolvency moratorium does not shield company officers from cheque dishonour prosecution for liability arising before corporate insolvency proceedings...
ITAT held that software subscription receipts were consideration for access to a copyrighted article, not royalty or fees for technical/included services, because customers received only a non-transferable right to use the software and no technology was transferred or made available. That treatment applied to AYs 2020-21 to 2022-23. By contrast, separate professional services receipts in AY 2022-23 were found to be specialised, customer-specific technical and professional consultations, so they were taxable as FTS/FIS under the Act and the DTAA. Proportionate equalization levy paid on those taxable services was directed to be refunded.
ITAT held that software subscription receipts were consideration for access to a copyrighted article, not royalty or fees for technical/included services, because customers received only a non-transferable right to use the software and no technology was transferred or made available. That treatment applied to AYs 2020-21 to 2022-23. By contrast, separate professional services receipts in AY 2022-23 were found to be specialised, customer-specific technical and professional consultations, so they were taxable as FTS/FIS under the Act and the DTAA. Proportionate equalization levy paid on those taxable services was directed to be refunded.
Note: It is a system-generated summary and is for quick reference only.
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