Tariff classification of vehicle gear components follows the specific gearing entry, displacing motor-vehicle parts classification and related liabili...
Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
Under the India-Singapore DTAA, research management support services qualify as fees for technical services only where they make available technical knowledge, skill, know-how or processes, or develop and transfer a technical plan or design that enables independent use by the recipient. Continued dependence on the service provider and merely incidental benefits do not establish such technology transfer. The notes state that the receipts were therefore business profits and not taxable in India without a permanent establishment. They also record that the limitation challenge to final assessments following the draft-assessment procedure failed because retrospectively operative provisions governed the assessment-completion period. Reopening and DIN-related issues remained open.
Under the India-Singapore DTAA, research management support services qualify as fees for technical services only where they make available technical knowledge, skill, know-how or processes, or develop and transfer a technical plan or design that enables independent use by the recipient. Continued dependence on the service provider and merely incidental benefits do not establish such technology transfer. The notes state that the receipts were therefore business profits and not taxable in India without a permanent establishment. They also record that the limitation challenge to final assessments following the draft-assessment procedure failed because retrospectively operative provisions governed the assessment-completion period. Reopening and DIN-related issues remained open.
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