Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
Technical know-how consideration payable by an Indian resident to a non-resident for use in its Indian business is chargeable to tax in India under source-based taxation of fees for technical services, including under the applicable treaty. Release of funds by a foreign grant administrator after certification of contractual claims merely discharges the resident's contractual liability; it does not change the resident payer's identity or the consideration's character. The location from which funds are remitted is not determinative. Tax deduction at source is therefore required, and non-deduction results in disallowance under Section 40(a)(i).
Technical know-how consideration payable by an Indian resident to a non-resident for use in its Indian business is chargeable to tax in India under source-based taxation of fees for technical services, including under the applicable treaty. Release of funds by a foreign grant administrator after certification of contractual claims merely discharges the resident's contractual liability; it does not change the resident payer's identity or the consideration's character. The location from which funds are remitted is not determinative. Tax deduction at source is therefore required, and non-deduction results in disallowance under Section 40(a)(i).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
