Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
Authorised courier due diligence protects against penalties where declared exports conceal prohibited goods despite proper documentation and customs p...
Customs-controlled container movement now extends to DP World facilities, subject to segregation, inspections, reconciliation, and EXIM cargo priority...
Management Service Agreement ("MSA") to its subsidiaries - the majority of the services are technical in nature and the remaining one are in the area of consultancy. Therefore, we cannot agree with the submission that they were only managerial in nature and not in the nature of technical or consultancy services. - However, only "direct technical advice, support and management including implementation" service provided under Information Technology (IT) service meets the requirement Of 'make available' in clause (c) of Article 13.4 under the treaty. Therefore, only this particular service is found to be in the nature of "fee for technical services" under Article 13.4(c) of India-UK Tax Treaty. - AAR
Management Service Agreement ("MSA") to its subsidiaries - the majority of the services are technical in nature and the remaining one are in the area of consultancy. Therefore, we cannot agree with the submission that they were only managerial in nature and not in the nature of technical or consultancy services. - However, only "direct technical advice, support and management including implementation" service provided under Information Technology (IT) service meets the requirement Of 'make available' in clause (c) of Article 13.4 under the treaty. Therefore, only this particular service is found to be in the nature of "fee for technical services" under Article 13.4(c) of India-UK Tax Treaty. - AAR
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
