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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Management and business support service fees paid to an Indian subsidiary were held not taxable as fees for technical services under the India-Singapore DTAA because the receipts did not satisfy the treaty's make available requirement in Article 12(4)(b). The treaty position was applied over the broader domestic definition of fees for technical services, and the addition was deleted. The Tribunal also relied on the unchanged service arrangement and the consistent view taken in earlier years in the same assessee's case, leaving the remaining grounds academic.
Management and business support service fees paid to an Indian subsidiary were held not taxable as fees for technical services under the India-Singapore DTAA because the receipts did not satisfy the treaty's make available requirement in Article 12(4)(b). The treaty position was applied over the broader domestic definition of fees for technical services, and the addition was deleted. The Tribunal also relied on the unchanged service arrangement and the consistent view taken in earlier years in the same assessee's case, leaving the remaining grounds academic.
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