Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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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