Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Royalty - Payment link charges / IPLC charges - there is no transfer of the right to use, either to the assessee or to CIS. The assessee has merely procured a service and provided the same to CIS, no part of equipment was leased out to CIS. Even otherwise, the payment is in the nature of reimbursement of expenses and accordingly not taxable in the hands of the assessee. - AT
Royalty - Payment link charges / IPLC charges - there is no transfer of the right to use, either to the assessee or to CIS. The assessee has merely procured a service and provided the same to CIS, no part of equipment was leased out to CIS. Even otherwise, the payment is in the nature of reimbursement of expenses and accordingly not taxable in the hands of the assessee. - AT
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