Admissibility of electronic evidence bars undervaluation demands where printouts, retracted statements and no cross-examination leave the case unprove...
Limitation in oppression and mismanagement proceedings: prior knowledge of removal and dilution barred the challenge, with valuation directions upheld...
Insolvency professional agency governance rules amended to add nominee directors, tighten independent director eligibility, and regulate managing dire...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
