Risk-based postal import clearance standardises electronic assessment, document requests, duty realisation and delivery controls at Foreign Post Offic...
Customs Cargo Service Provider appointment extends custodianship to additional terminal land, subject to cargo-control, security and licence condition...
Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
Income accrued in India - Fee for Technical/Included Services - whether the amount received by the assessee for various services, commonly known as centralized services, will fall within the ambit of FIS under Article 12(4)(a) of the Treaty? - the fee received by the assessee under the Centralized Services Agreement cannot be treated as FIS either under Article 12(4)(a) or 12(4)(b) of the India–US Tax Treaty. As a natural corollary, it can only be treated as business income of the assessee. Hence, in absence of a PE in India, it will not be taxable. - AT
Income accrued in India - Fee for Technical/Included Services - whether the amount received by the assessee for various services, commonly known as centralized services, will fall within the ambit of FIS under Article 12(4)(a) of the Treaty? - the fee received by the assessee under the Centralized Services Agreement cannot be treated as FIS either under Article 12(4)(a) or 12(4)(b) of the India–US Tax Treaty. As a natural corollary, it can only be treated as business income of the assessee. Hence, in absence of a PE in India, it will not be taxable. - AT
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