Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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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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