Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction sche...
Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
Income taxable in India - taxability of receipts from business support services as Fee - Since, the Revenue has failed to demonstrate before us that in course of rendition of services, the assessee has made available technical knowledge, knowhow, skill etc. to the recipient of service, we are unable to upheld the nature and character of receipt as FTS, even under Article 12(4)(b) of India – Portugal DTAA. Thus, in our view, the amount cannot be treated as FTS under the treaty provisions. - AT
Income taxable in India - taxability of receipts from business support services as Fee - Since, the Revenue has failed to demonstrate before us that in course of rendition of services, the assessee has made available technical knowledge, knowhow, skill etc. to the recipient of service, we are unable to upheld the nature and character of receipt as FTS, even under Article 12(4)(b) of India – Portugal DTAA. Thus, in our view, the amount cannot be treated as FTS under the treaty provisions. - AT
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