Just a moment...

⚠✕
❮ Top
☎ Help
☰
×

By creating an account you can:

Logo TaxTMI
Keyword Search :
AI Tools : New
Ask tax questions in natural language. Powered by AI trained on the TaxTMI legal database. Use AI Tools ➞
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters0/2000
Make Most of Text Search ✕
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
    6. Text Search
  6. The system will try to fetch results that contains ALL your words.
  7. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
    8. Text Search
╳
Add to...
You have not created any category. Kindly create one to bookmark this item!
✕
Create New Category
Hide
Title :
Description :
❮❮ Hide
❮ Default View
Expand ❯❯
Close ✕
🔎 Highlights - Adv. Search ❯
TEXT SEARCH:

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In:
Main Text + AI Text ❯
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws----❯
  • ---- All Laws----
  • Income Tax
  • Direct Taxes
  • Benami Property
  • Central GST Laws
  • SGST - State GST Laws
  • Customs
  • FTP - Foreign Trade Policy
  • SEZ - Special Economic Zone
  • FEMA - Foreign Exchange Management
  • Companies Law
  • SEBI - Securities & Exchange Board of India
  • IBC - Insolvency and Bankruptcy
  • Law of Competition
  • PMLA - Money-Laundering
  • Indian Laws
  • Bill / Finance Bills
  • Wealth Tax
  • Service Tax
  • Central Excise
  • VAT / Sales Tax
Month:
---- All Months ----❯
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ----❯
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
RelevanceDefaultDate
    July 28, 2026   Case LawsGST
    GST appellate remand prohibition makes unauthorised remand a jurisdictional nullity, preserving writ review despite rectification and alternative-reme...
    July 28, 2026   Case LawsGST
    Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
    July 28, 2026   Case LawsGST
    Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
    July 28, 2026   Case LawsGST
    Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
    July 28, 2026   Case LawsIncome Tax
    Redemption premium on business-funding FCCBs is revenue expenditure and may be spread across the prescribed maturity period.
    July 28, 2026   Case LawsIncome Tax
    Pre-commencement project receipts remain capital when tied to installation, while infrastructure deductions follow the taxpayer's chosen initial year.
    July 28, 2026   Case LawsIncome Tax
    Tax deducted at source must be considered before prosecuting delayed return filing where the statutory exception applies.
    July 28, 2026   Case LawsIncome Tax
    Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
    July 28, 2026   Case LawsIncome Tax
    Notional interest under mercantile accounting cannot be imputed where debtors lack business activity and interest recovery is unsupported.
    July 28, 2026   Case LawsIncome Tax
    India-Netherlands treaty taxation: executive search fees and cost reimbursements may fall outside technical services taxation.
    July 28, 2026   Case LawsIncome Tax
    Kachha arhtia turnover excludes principals' sale proceeds; tax-audit penalty fails where no books existed for audit.
    July 28, 2026   Case LawsIncome Tax
    Foreign income taxed in final settlement proceedings cannot be reassessed under the Black Money Act, preventing double taxation.
    July 28, 2026   Case LawsIncome Tax
    Outright software purchases treated as business profits, eliminating withholding where the foreign seller lacks an Indian permanent establishment.
    July 28, 2026   Case LawsIncome Tax
    Interest on partners' running accounts and lender accruals remains deductible where tax is deducted and recipients report income.
    July 28, 2026   Case LawsIncome Tax
    Business closure expenditure fails the section 37(1) test, while unsupported estimated foreign exchange loss disallowance cannot stand.
    July 28, 2026   Case LawsIncome Tax
    Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
    July 28, 2026   Case LawsIncome Tax
    Interest accrual, related investment disallowance, loan genuineness and unquoted-share valuation govern the respective tax adjustments and remand.
    July 28, 2026   Case LawsIncome Tax
    Independent corroboration and proven nexus govern additions based on retracted statements, loose sheets, and third-party records.
    July 28, 2026   Case LawsIncome Tax
    Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
    July 28, 2026   Case LawsIncome Tax
    Bad-debt deduction for share-broking client dues is available on account write-off without proving actual irrecoverability.
❮
❯
❯❯
MaximizeMaximizeMaximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

    +

    Are you sure you want to delete "My most important" ?

    NOTE:

    Open Link
    Highlights
    Showing Results for :
    Reset Filters
    Results Found:
    Show All SummariesHide All Summaries
    July 28, 2026   Case Laws GST
    GST appellate remand prohibition makes unauthorised remand a jurisdictional nullity, preserving writ review despite rectification and alternative-remedy objections.
    July 28, 2026   Case Laws GST
    Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate authorisation.
    July 28, 2026   Case Laws GST
    Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustainable.
    July 28, 2026   Case Laws GST
    Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities exist.
    July 28, 2026   Case Laws Income Tax
    Redemption premium on business-funding FCCBs is revenue expenditure and may be spread across the prescribed maturity period.
    July 28, 2026   Case Laws Income Tax
    Pre-commencement project receipts remain capital when tied to installation, while infrastructure deductions follow the taxpayer's chosen initial year.
    July 28, 2026   Case Laws Income Tax
    Tax deducted at source must be considered before prosecuting delayed return filing where the statutory exception applies.
    July 28, 2026   Case Laws Income Tax
    Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relevant date.
    July 28, 2026   Case Laws Income Tax
    Notional interest under mercantile accounting cannot be imputed where debtors lack business activity and interest recovery is unsupported.
    July 28, 2026   Case Laws Income Tax
    India-Netherlands treaty taxation: executive search fees and cost reimbursements may fall outside technical services taxation.
    July 28, 2026   Case Laws Income Tax
    Kachha arhtia turnover excludes principals' sale proceeds; tax-audit penalty fails where no books existed for audit.
    July 28, 2026   Case Laws Income Tax
    Foreign income taxed in final settlement proceedings cannot be reassessed under the Black Money Act, preventing double taxation.
    July 28, 2026   Case Laws Income Tax
    Outright software purchases treated as business profits, eliminating withholding where the foreign seller lacks an Indian permanent establishment.
    July 28, 2026   Case Laws Income Tax
    Interest on partners' running accounts and lender accruals remains deductible where tax is deducted and recipients report income.
    July 28, 2026   Case Laws Income Tax
    Business closure expenditure fails the section 37(1) test, while unsupported estimated foreign exchange loss disallowance cannot stand.
    July 28, 2026   Case Laws Income Tax
    Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported adjustments failed.
    July 28, 2026   Case Laws Income Tax
    Interest accrual, related investment disallowance, loan genuineness and unquoted-share valuation govern the respective tax adjustments and remand.
    July 28, 2026   Case Laws Income Tax
    Independent corroboration and proven nexus govern additions based on retracted statements, loose sheets, and third-party records.
    July 28, 2026   Case Laws Income Tax
    Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual business use.
    July 28, 2026   Case Laws Income Tax
    Bad-debt deduction for share-broking client dues is available on account write-off without proving actual irrecoverability.

    Highlights

    Back

    All Highlights

    Showing Results for :
    Reset Filters
      No Records Found

      Highlights

      Home› Highlights › Income Tax › 2023 › September, 2023 › This
      Back

      All Highlights

      whatsappJoin Channel
      Showing Results for : Reset Filters
      Income Tax

      Taxability as Fee for Included Service (FIS) u/A 12 of India-USA...

      India-USA DTAA: Technical Skill Use Alone Doesn't Qualify as Fee for Technical Services Under Article 12.

      Contents
      Summary
      Note

      Note

      -

      Bookmark

      Print

      Print

      Print Options

      Income TaxSeptember 2, 2023Case LawsAT
      Taxability as Fee for Included Service (FIS) u/A 12 of India-USA DTAA - As per Example 7 of the Memorandum of Understanding to India-USA DTAA, a receipt cannot be treated as FTS merely because the service provider while providing consultancy services has used substantial technical skill and expertise. Because, while providing such services, the American Company is not making available to the Indian Company, any technical expertise, knowledge or skill etc. but is merely transferring commercial information to the Indian Company by utilizing technical skill. - AT
      View Source View

      Topics

      ActsIncome Tax
      Next ➔