Foreign portfolio investment liberalisation extends listed equity access to all individual persons resident outside India, subject to limit monitoring...
Unsubstantiated exempt agricultural income claim sustains concealment penalty after disclosure only on departmental detection and no bona fide evidenc...
Income deemed to accrue or arise in India - amounts received by the assessee from its Indian subsidiary towards IT and SAP charges - the services rendered under IT and SAP Services Agreement are not ancillary and subsidiary to the services rendered under the Technical Collaboration Agreement. Moreso, when the IT and SAP Services Agreement was in existence much prior to the Technical Collaboration Agreement. - The receipts in dispute cannot be treated as FTS under Article 12(4)(a) of India – Portugal DTAA - AT
Income deemed to accrue or arise in India - amounts received by the assessee from its Indian subsidiary towards IT and SAP charges - the services rendered under IT and SAP Services Agreement are not ancillary and subsidiary to the services rendered under the Technical Collaboration Agreement. Moreso, when the IT and SAP Services Agreement was in existence much prior to the Technical Collaboration Agreement. - The receipts in dispute cannot be treated as FTS under Article 12(4)(a) of India – Portugal DTAA - AT
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