Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
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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