Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
SaaS subscription receipts from Indian customers for a standard,...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscription expiry.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
SaaS subscription receipts from Indian customers for a standard, non-customised software development kit and dashboard facility did not constitute fees for included services under Article 12(4) of the India-USA DTAA. Customers integrated the product and generated reports independently, while the provider retained its algorithms, source code and processes; use of technology did not make technical knowledge available for independent post-subscription use. Incidental account management, support and demonstrations did not change the transaction's predominant automated character. The related additions were deleted for both assessment years. Tax deducted at source credit required Assessing Officer verification before grant, and the challenge to penalty initiation for under-reporting was premature.
SaaS subscription receipts from Indian customers for a standard, non-customised software development kit and dashboard facility did not constitute fees for included services under Article 12(4) of the India-USA DTAA. Customers integrated the product and generated reports independently, while the provider retained its algorithms, source code and processes; use of technology did not make technical knowledge available for independent post-subscription use. Incidental account management, support and demonstrations did not change the transaction's predominant automated character. The related additions were deleted for both assessment years. Tax deducted at source credit required Assessing Officer verification before grant, and the challenge to penalty initiation for under-reporting was premature.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
