Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
TDS u/s 195 - site testing charges - Royalty - the services which can independently or on stand alone basis, be provided, coupled with the fulfillment of the other requirement of Para 4(b) of the DTAA would only attract the ‘Fee for included services' - In the present case, the services, which are the subject matter of the dispute, do not fall under “Fee for incidental services”, hence, would not fall under Royalty and as such, not chargeable in India as per Clause 12 of DTAA - AT
TDS u/s 195 - site testing charges - Royalty - the services which can independently or on stand alone basis, be provided, coupled with the fulfillment of the other requirement of Para 4(b) of the DTAA would only attract the ‘Fee for included services' - In the present case, the services, which are the subject matter of the dispute, do not fall under “Fee for incidental services”, hence, would not fall under Royalty and as such, not chargeable in India as per Clause 12 of DTAA - AT
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