Fair-rent assessment requires consideration of lease terms, valuation principles and prevailing market rent; the certificate was quashed for fresh rev...
Document Identification Number compliance is satisfied when electronically communicated orders are promptly authenticated through a correctly identifi...
Industrial shrimp-feed machinery classification follows its commercial function, placing integrated production plants under the specific industrial fo...
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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