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    October 1, 2026   Case Laws Income Tax
    Notional interest on delayed associated-enterprise receivables may require no separate adjustment where the taxpayer is entirely debt-free.
    October 1, 2026   Case Laws Income Tax
    Third-Party Search Material Cannot Extend Reassessment Limitation Where the Applicable Search Assessment Block Has Expired.
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    Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
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    Additional evidence and verification govern disputed creditor balances, agricultural claims, sales rebates, and share application money taxability.
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    Transfer-pricing tolerance band applies to a single-value internal comparable, treating the declared price as arm's length.
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    October 1, 2026   Case Laws Customs
    Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
    October 1, 2026   Case Laws Customs
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    September 30, 2026   Notes GST
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    September 30, 2026   Notifications Income Tax
    Scientific research association approval requires continuing SIRO status, annual donation reporting, and donor certificates for the approved foundatio...
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    September 30, 2026   Notifications Income Tax
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October 1, 2026   Case Laws Income Tax
Notional interest on delayed associated-enterprise receivables may require no separate adjustment where the taxpayer is entirely debt-free.
October 1, 2026   Case Laws Income Tax
Third-Party Search Material Cannot Extend Reassessment Limitation Where the Applicable Search Assessment Block Has Expired.
October 1, 2026   Case Laws Income Tax
Search penalty requires statutory undisclosed-income finding, precise default notice, and timely completion after assessment appeal.
October 1, 2026   Case Laws Income Tax
Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional interest.
October 1, 2026   Case Laws Income Tax
Additional evidence and verification govern disputed creditor balances, agricultural claims, sales rebates, and share application money taxability.
October 1, 2026   Case Laws Income Tax
Transfer-pricing tolerance band applies to a single-value internal comparable, treating the declared price as arm's length.
October 1, 2026   Case Laws Income Tax
Pecuniary jurisdiction governs scrutiny notices: an ACIT notice without transfer can invalidate the resulting assessment.
October 1, 2026   Case Laws Customs
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties.
October 1, 2026   Case Laws Customs
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and penalties.
October 1, 2026   Case Laws IBC
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of disciplinary proceedings.
October 1, 2026   Case Laws IBC
One-Time Settlement Default Does Not Reset Insolvency Default Date, Limiting Section 10A Bar and Preserving Admission
October 1, 2026   Case Laws Money Laundering
Equivalent-value property attachment may reach pre-existing assets when direct proceeds of crime are unavailable or laundered.
October 1, 2026   Case Laws Service Tax
Foreign-bank charges under reverse charge require exporter privity; unsegregated demands, extended limitation and penalties fail.
October 1, 2026   Case Laws Wealth-tax
Agricultural-land exclusion under wealth tax extends retrospectively to revenue-record agricultural land used for agricultural purposes.
September 30, 2026   Notes IBC
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation and voting.
September 30, 2026   Notes GST
Extended GST limitation permits distinct scrutiny-based demands despite prior audit, but requires fraud, wilful misstatement, or tax-evasive suppression.
September 30, 2026   Notes GST
Blocked construction input tax credit persists despite taxable rental income, subject only to proven plant or structural-support exceptions.
September 30, 2026   Notifications Income Tax
Scientific research association approval requires continuing SIRO status, annual donation reporting, and donor certificates for the approved foundation.
September 30, 2026   Notifications Income Tax
Scientific research institution approval applies subject to SIRO recognition, prescribed reporting, and donor certification requirements.
September 30, 2026   Notifications Income Tax
Scientific research institution approval is conditional on SIRO recognition, annual donation reporting, donor certification, and prescribed compliance.

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

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Income Tax September 2, 2023 Case Laws AT
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
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