Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
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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