Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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Royalty - Taxability of receipts on hire of vessel on time charter basis - as the assessee had received charges on account of time charter services rendered by its vessel ‘Smit Borneo’ along with the crew to Leighton India Contractor Pvt. Ltd., and not for allowing the latter the ‘use’ or ‘right to use’ of industrial, commercial, or scientific equipment, the same therein cannot be treated as ‘royalty’ within the meaning of Article 12(3)(b) of the India-Singapore tax treaty. - AT
Royalty - Taxability of receipts on hire of vessel on time charter basis - as the assessee had received charges on account of time charter services rendered by its vessel ‘Smit Borneo’ along with the crew to Leighton India Contractor Pvt. Ltd., and not for allowing the latter the ‘use’ or ‘right to use’ of industrial, commercial, or scientific equipment, the same therein cannot be treated as ‘royalty’ within the meaning of Article 12(3)(b) of the India-Singapore tax treaty. - AT
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