Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
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.
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