Belated Form 10B filing during Covid-19 cannot defeat charitable exemption where genuine hardship warrants condonation and substantial justice prevail...
Limitation for consequential assessments runs from prescribed authority receipt, while verified purchases cannot be disallowed merely for unanswered s...
Higher depreciation for qualifying commercial vehicles, exempt-income disallowance, research deduction verification, and club-expense treatment clarif...
Charitable registration renewal cannot become an assessment of receipts, profitability or annual exemption compliance, requiring renewal and donation ...
AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
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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.
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