Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter...
Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
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Article 8 of the India-UK DTAA limits exemption to profits from operating aircraft in international traffic, activities directly connected with that transportation, and qualifying participation in airline pools. The notes state that ground handling and engineering services rendered to other airlines were treated as an organised commercial activity, not directly connected with the airline's own aircraft operations, and no qualifying pool participation was established. Receipts from those services were therefore taxable in India and outside Article 8 for the relevant assessment years. Decisions under the India-Germany and India-Netherlands treaties were distinguished because their provisions were wider, while OECD commentary was stated not to be binding.
Article 8 of the India-UK DTAA limits exemption to profits from operating aircraft in international traffic, activities directly connected with that transportation, and qualifying participation in airline pools. The notes state that ground handling and engineering services rendered to other airlines were treated as an organised commercial activity, not directly connected with the airline's own aircraft operations, and no qualifying pool participation was established. Receipts from those services were therefore taxable in India and outside Article 8 for the relevant assessment years. Decisions under the India-Germany and India-Netherlands treaties were distinguished because their provisions were wider, while OECD commentary was stated not to be binding.
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