Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
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.
Note: It is a system-generated summary and is for quick reference only.