Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
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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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