Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
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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