Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
Customs Broker licence proceedings require accurate procedural facts before delay or natural-justice findings can justify setting aside regulatory act...
Provisional assessment finalisation must precede export duty recovery, while redemption fine fails for goods already exported and unavailable for conf...
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.
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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