Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter...
Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
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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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