Strict construction of customs exemptions denied concession for brake components, while limitation restricted differential duty to timely Bills of Ent...
Way Leave Permissions cannot be retrospectively revived through insolvency plans, and affected infrastructure holders require safety review and hearin...
Inter-terminal container movement requires customs escort, permit reconciliation, and indemnity, while delayed DPD cargo may move to designated CFS ya...
Diamond grading and certification charges for examining diamonds and issuing reports of their physical characteristics do not constitute fees for technical services merely because the provider uses specialised knowledge, equipment or qualified personnel. Where the service neither imparts managerial, technical or consultancy advice nor enables the recipient to perform diamond grading independently, the treaty "make available" condition is not met. Payments not chargeable to tax in India do not trigger withholding obligations on payments to non-residents. Accordingly, the demand for failure to deduct tax and consequential interest was deleted, and the Revenue's appeals were dismissed.
Diamond grading and certification charges for examining diamonds and issuing reports of their physical characteristics do not constitute fees for technical services merely because the provider uses specialised knowledge, equipment or qualified personnel. Where the service neither imparts managerial, technical or consultancy advice nor enables the recipient to perform diamond grading independently, the treaty "make available" condition is not met. Payments not chargeable to tax in India do not trigger withholding obligations on payments to non-residents. Accordingly, the demand for failure to deduct tax and consequential interest was deleted, and the Revenue's appeals were dismissed.
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