Market value for captive electricity consumption follows industrial consumer tariffs, supporting profit computation for the power generation deduction...
Provisional release of seized imports requires enhanced duty payment, bank guarantee and disclosures while customs adjudication proceeds independently...
Diamond grading and certification payments to non-resident laboratories are analysed as consideration for independent examination and reporting of a diamond's physical characteristics, rather than managerial, technical or consultancy services. The use of specialised personnel or equipment does not alone convert such payments into fees for technical services. Under the India-USA and India-UK treaty provisions on fees for included services, a grading report does not "make available" technical knowledge, skill, know-how or a process because it does not enable the recipient to conduct future grading independently. In the absence of a permanent establishment, the payments are discussed as business profits not chargeable to tax in India, with no related withholding obligation.
Diamond grading and certification payments to non-resident laboratories are analysed as consideration for independent examination and reporting of a diamond's physical characteristics, rather than managerial, technical or consultancy services. The use of specialised personnel or equipment does not alone convert such payments into fees for technical services. Under the India-USA and India-UK treaty provisions on fees for included services, a grading report does not "make available" technical knowledge, skill, know-how or a process because it does not enable the recipient to conduct future grading independently. In the absence of a permanent establishment, the payments are discussed as business profits not chargeable to tax in India, with no related withholding obligation.
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