Related-party creditor exclusion bars CoC participation where lender rights show policy-making involvement, and post-CIRP assignment cannot cure ineli...
Rectification of apparent typographical errors may proceed without hearing when tax liability, input tax credit, and ruling substance remain unchanged...
Article 12(5)(c) of the India-USA DTAA, operating through a non-obstante clause, excludes consideration for teaching in or by educational institutions from Fees for Included Services, even if the service could otherwise fall within Article 12(4). Technical or professionally oriented courses, including customised instruction for corporate employees, retain their educational character where knowledge is imparted to participants. Non-credit status, delivery outside a campus, and an audience of working professionals do not by themselves alter that character. Equalisation Levy treatment under a separate fiscal regime does not change the treaty character of educational-course receipts.
Article 12(5)(c) of the India-USA DTAA, operating through a non-obstante clause, excludes consideration for teaching in or by educational institutions from Fees for Included Services, even if the service could otherwise fall within Article 12(4). Technical or professionally oriented courses, including customised instruction for corporate employees, retain their educational character where knowledge is imparted to participants. Non-credit status, delivery outside a campus, and an audience of working professionals do not by themselves alter that character. Equalisation Levy treatment under a separate fiscal regime does not change the treaty character of educational-course receipts.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
