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    October 6, 2026   Case Laws Income Tax
    Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
    October 6, 2026   Case Laws Income Tax
    Appeal Filing Does Not Stay Tax Recovery, Though Further Recovery May Pause During First Appeal
    October 6, 2026   Case Laws Income Tax
    Recorded satisfaction before Rule 8D application bars additional exempt-income expense disallowance and preserves voluntary taxpayer computation.
    October 6, 2026   Case Laws Income Tax
    Customer-referral commission is business income, not fees for technical services, where no know-how is made available.
    October 6, 2026   Case Laws Income Tax
    Cash-payment disallowance requires verified statutory conditions; unreliable civil-contractor books may instead support estimated business income.
    October 6, 2026   Case Laws Income Tax
    Berry Ratio rejected for jewellery manufacturing; receivables interest depends on customer-credit parity and binding book-profit directions.
    October 6, 2026   Case Laws Income Tax
    Jurisdictional satisfaction for concealment penalty cannot be created later by substituting a distinct penal provision after assessment.
    October 6, 2026   Case Laws Income Tax
    Delayed trade receivables require independent arm's length benchmarking after the agreed credit period, using currency-appropriate interest rates.
    October 6, 2026   Case Laws Income Tax
    Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
    October 6, 2026   Case Laws Income Tax
    Arm's length pricing of captive electricity follows the distribution licensee's supply rate, while penalty initiation challenges remain premature.
    October 6, 2026   Case Laws Income Tax
    Pass-through associated enterprise purchases require no arm's length adjustment where credit notes align prices with the unrelated supplier.
    October 6, 2026   Case Laws Income Tax
    Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
    October 6, 2026   Case Laws Income Tax
    Tax withholding on settlement compensation requires an identified statutory obligation before a disallowance can arise.
    October 6, 2026   Case Laws Income Tax
    Compulsorily convertible debentures remain debt until conversion, preventing transfer-pricing recharacterisation as equity without the GAAR procedure.
    October 6, 2026   Case Laws Income Tax
    Reciprocal plot exchanges: Consideration in kind prevents section 43CA valuation addition where no stamp-duty shortfall exists.
    October 6, 2026   Case Laws Customs
    Project-import contract registration before importation determines Heading 98.01 eligibility, while Section 18A permits qualifying post-clearance Bill...
    October 6, 2026   Case Laws IBC
    Clean slate protection prevents enforcement of pre-CIRP export obligations through Denied Entry List restrictions after resolution approval.
    October 6, 2026   Case Laws IBC
    Resolution-plan feasibility fails where SEZ land conversion lacks consent and the Information Memorandum conceals regulatory uncertainty.
    October 6, 2026   Case Laws GST
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    October 6, 2026   Case Laws GST
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October 6, 2026   Case Laws Income Tax
Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of stale proceedings.
October 6, 2026   Case Laws Income Tax
Appeal Filing Does Not Stay Tax Recovery, Though Further Recovery May Pause During First Appeal
October 6, 2026   Case Laws Income Tax
Recorded satisfaction before Rule 8D application bars additional exempt-income expense disallowance and preserves voluntary taxpayer computation.
October 6, 2026   Case Laws Income Tax
Customer-referral commission is business income, not fees for technical services, where no know-how is made available.
October 6, 2026   Case Laws Income Tax
Cash-payment disallowance requires verified statutory conditions; unreliable civil-contractor books may instead support estimated business income.
October 6, 2026   Case Laws Income Tax
Berry Ratio rejected for jewellery manufacturing; receivables interest depends on customer-credit parity and binding book-profit directions.
October 6, 2026   Case Laws Income Tax
Jurisdictional satisfaction for concealment penalty cannot be created later by substituting a distinct penal provision after assessment.
October 6, 2026   Case Laws Income Tax
Delayed trade receivables require independent arm's length benchmarking after the agreed credit period, using currency-appropriate interest rates.
October 6, 2026   Case Laws Income Tax
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated facts.
October 6, 2026   Case Laws Income Tax
Arm's length pricing of captive electricity follows the distribution licensee's supply rate, while penalty initiation challenges remain premature.
October 6, 2026   Case Laws Income Tax
Pass-through associated enterprise purchases require no arm's length adjustment where credit notes align prices with the unrelated supplier.
October 6, 2026   Case Laws Income Tax
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the actual transfer year.
October 6, 2026   Case Laws Income Tax
Tax withholding on settlement compensation requires an identified statutory obligation before a disallowance can arise.
October 6, 2026   Case Laws Income Tax
Compulsorily convertible debentures remain debt until conversion, preventing transfer-pricing recharacterisation as equity without the GAAR procedure.
October 6, 2026   Case Laws Income Tax
Reciprocal plot exchanges: Consideration in kind prevents section 43CA valuation addition where no stamp-duty shortfall exists.
October 6, 2026   Case Laws Customs
Project-import contract registration before importation determines Heading 98.01 eligibility, while Section 18A permits qualifying post-clearance Bill revisions.
October 6, 2026   Case Laws IBC
Clean slate protection prevents enforcement of pre-CIRP export obligations through Denied Entry List restrictions after resolution approval.
October 6, 2026   Case Laws IBC
Resolution-plan feasibility fails where SEZ land conversion lacks consent and the Information Memorandum conceals regulatory uncertainty.
October 6, 2026   Case Laws GST
GST limitation turns on issuance of substantive notices and orders, not later electronic DRC summaries, preserving appellate review.
October 6, 2026   Case Laws GST
Rule 138B authorisation and alternative appellate remedies limited the writ challenge to confiscation proceedings involving scrap-goods transport.

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Home › Highlights › Income Tax › 2019 › March, 2019 › This
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Income Tax

Income accrued in India - Taxability of the receipts of...

Non-Resident Technical Service Fees in India Taxable u/s 44BB, Per DTAA with Netherlands, Australia, USA, Russia.

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Income Tax March 20, 2019 Case Laws AT
Income accrued in India - Taxability of the receipts of non-resident in India - fees for technical services as per the provisions of the DTAA or as per the provisions of section 44BB - India and DTAA with Netherlands, Australia, USA & Russia - scope of ‘make available’ clause - To be Taxable u/s 44BB only.
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