Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Pre-existing disputes over outcome-based professional fees can bar Section 9 insolvency proceedings where contractual entitlement requires investigati...
Corresponding scheduled offences preserve money-laundering jurisdiction despite repeal of the central corruption provision where conduct remains cover...
Market data charges recovered from Indian associated enterprises were not taxable as royalty under the India-USA DTAA, as the facts and legal position matched earlier Tribunal decisions and no distinction was established. The related addition was deleted. Reimbursements of salary and employee-related costs for seconded employees were likewise not treated as fees for included services or fees for technical services under the India-USA DTAA, following an earlier Tribunal ruling on comparable expense recoveries. The addition for employee-related reimbursements was deleted, while interest was to be levied consequentially in accordance with law.
Market data charges recovered from Indian associated enterprises were not taxable as royalty under the India-USA DTAA, as the facts and legal position matched earlier Tribunal decisions and no distinction was established. The related addition was deleted. Reimbursements of salary and employee-related costs for seconded employees were likewise not treated as fees for included services or fees for technical services under the India-USA DTAA, following an earlier Tribunal ruling on comparable expense recoveries. The addition for employee-related reimbursements was deleted, while interest was to be levied consequentially in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
