Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Royalty and licence fees may be included in the customs transaction value only where Revenue establishes a direct and proximate relationship with the imported goods and proves that payment is a condition of their sale. The explanation concerning post-import processing does not independently expand these requirements. Royalties payable for technology transfer, intellectual property, or post-import manufacturing rights are not linked to imports merely through a broad commercial connection. Where royalty arises from manufacture and sale of finished products, is neither conditional on component imports nor calculated by their value or quantity, it is not includible in the assessable value of imported components.
Royalty and licence fees may be included in the customs transaction value only where Revenue establishes a direct and proximate relationship with the imported goods and proves that payment is a condition of their sale. The explanation concerning post-import processing does not independently expand these requirements. Royalties payable for technology transfer, intellectual property, or post-import manufacturing rights are not linked to imports merely through a broad commercial connection. Where royalty arises from manufacture and sale of finished products, is neither conditional on component imports nor calculated by their value or quantity, it is not includible in the assessable value of imported components.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
