Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
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Offshore supply profits from equipment, integrated designs and spares manufactured, delivered FOB and paid for outside India were not taxable in India where title passed abroad, no fixed-place PE was established, and the supervisory PE had no connection with the supplies. The attribution of those profits was deleted. Supervisory services exceeding the treaty duration threshold created a supervisory PE; receipts directly connected with it were taxable as net business profits under Article 7, not gross-basis fees for technical services. Offshore designs and drawings supplied solely for internal plant use transferred no right to commercially exploit intellectual property and were business income, not royalty or fees for technical services. Advance-tax interest was not chargeable for the relevant period, while return-delay interest and tax-deduction credit required verification.
Offshore supply profits from equipment, integrated designs and spares manufactured, delivered FOB and paid for outside India were not taxable in India where title passed abroad, no fixed-place PE was established, and the supervisory PE had no connection with the supplies. The attribution of those profits was deleted. Supervisory services exceeding the treaty duration threshold created a supervisory PE; receipts directly connected with it were taxable as net business profits under Article 7, not gross-basis fees for technical services. Offshore designs and drawings supplied solely for internal plant use transferred no right to commercially exploit intellectual property and were business income, not royalty or fees for technical services. Advance-tax interest was not chargeable for the relevant period, while return-delay interest and tax-deduction credit required verification.
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