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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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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