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...
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.
Note: It is a system-generated summary and is for quick reference only.
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