Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
Toy balloon tariff classification: functional heading prevails over residual rubber and festive article headings, supporting penalties for deliberate ...
Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent...
Payments for a non-exclusive, non-transferable and non-sublicensable licence to use software internally do not constitute royalty under Article 12(3) of the India-USA DTAA where the licensor retains copyright and proprietary rights and the user cannot commercially exploit, modify, sublicense, reverse engineer or copy the software except for backup. Such payments concern use of a copyrighted article, eliminating withholding-tax liability as royalty. Payments for video-conferencing equipment and allied products are not fees for technical services merely because installation, setup and training accompany the supply. Withholding applies only to the separately identified installation, setup and training component, subject to the applicable India-Germany DTAA rate.
Payments for a non-exclusive, non-transferable and non-sublicensable licence to use software internally do not constitute royalty under Article 12(3) of the India-USA DTAA where the licensor retains copyright and proprietary rights and the user cannot commercially exploit, modify, sublicense, reverse engineer or copy the software except for backup. Such payments concern use of a copyrighted article, eliminating withholding-tax liability as royalty. Payments for video-conferencing equipment and allied products are not fees for technical services merely because installation, setup and training accompany the supply. Withholding applies only to the separately identified installation, setup and training component, subject to the applicable India-Germany DTAA rate.
Note: It is a system-generated summary and is for quick reference only.