Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
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Taxability of receipts from non-customised software, SaaS and related services under the India-Ireland DTAA depends on whether automated facilities involve the requisite human element and constitute specialised services rather than standard facilities available to all users. The note distinguishes this fees-for-technical-services inquiry from software royalty analysis under the India-USA DTAA and identifies the need to examine customer-specific service delivery, training and reseller involvement. Where such receipts are taxable, the beneficial treaty rate applies without surcharge or education cess. It also addresses statutory interest on refunds and verification of TDS adjustment.
Taxability of receipts from non-customised software, SaaS and related services under the India-Ireland DTAA depends on whether automated facilities involve the requisite human element and constitute specialised services rather than standard facilities available to all users. The note distinguishes this fees-for-technical-services inquiry from software royalty analysis under the India-USA DTAA and identifies the need to examine customer-specific service delivery, training and reseller involvement. Where such receipts are taxable, the beneficial treaty rate applies without surcharge or education cess. It also addresses statutory interest on refunds and verification of TDS adjustment.
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