Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Income accrued in India - TDS u/s 195 - fees for included services (FTS) - USA DTAA - the PGCIL would not apply technology on its own. It would continue to depend on the assessee for provision of software and hardware maintenance and support services in the future. Thus, keeping in view of the facts and circumstances of the case, receipts from PGCIL do not qualify as 'fees for included services' under articles 12(4)(a) and 12(4)(b) of India - US DTAA. - AT
Income accrued in India - TDS u/s 195 - fees for included services (FTS) - USA DTAA - the PGCIL would not apply technology on its own. It would continue to depend on the assessee for provision of software and hardware maintenance and support services in the future. Thus, keeping in view of the facts and circumstances of the case, receipts from PGCIL do not qualify as 'fees for included services' under articles 12(4)(a) and 12(4)(b) of India - US DTAA. - AT
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TaxTMI 
TaxTMI 
