Faceless assessment and registration procedures are updated through electronic communication, revised recovery rules, extended deadlines, and replacem...
Risk-based selective vessel boarding requires accurate declarations and preserves master and agent liability where physical inspections are not select...
Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Income received from sale of software licenses - Royalty - the amended definition of Royalty under the domestic law even if amended with retrospective effect cannot be extended to the definition of “Royalty” under the DTAA since the term “Royalty” under the DTAA has not been amended. As the provision of DTAA over-ride the provision of Income Tax Act, 1961 and being more beneficial shall apply - AT
Income received from sale of software licenses - Royalty - the amended definition of Royalty under the domestic law even if amended with retrospective effect cannot be extended to the definition of “Royalty” under the DTAA since the term “Royalty” under the DTAA has not been amended. As the provision of DTAA over-ride the provision of Income Tax Act, 1961 and being more beneficial shall apply - AT
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