Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
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Subscription charges for access to copyrighted databases and online journals are not royalty where users may only search, view and display content for personal use. Access that confers no right to reproduce, amend, replicate or commercially exploit content does not amount to use of, or a right to use, copyright; it is consideration for a copyrighted article or product. Absence of control or dominion over servers also prevents classification as payment for use of industrial, commercial or scientific equipment. Accordingly, the subscription revenue was not taxable as royalty under domestic law or the India-US DTAA, and the related addition was deleted.
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