Statutory refund interest requires correction of short computation and compensation where admitted interest remains unpaid through administrative dela...
Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
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Income accrued in India - engineering package fee and on-site man-day charges - the service rendered by the assessee is in connection with installation/erection of plant and machinery involved in mining of natural resources - Scope of Article 5(2)(g) of India-Portugal DTAA is not merely limited to mining or extraction of natural resources but also covers installation or structure used for exploration and exploitation of nature resources. - The amount paid would not qualify as FTS. - Demand set aside - AT
Income accrued in India - engineering package fee and on-site man-day charges - the service rendered by the assessee is in connection with installation/erection of plant and machinery involved in mining of natural resources - Scope of Article 5(2)(g) of India-Portugal DTAA is not merely limited to mining or extraction of natural resources but also covers installation or structure used for exploration and exploitation of nature resources. - The amount paid would not qualify as FTS. - Demand set aside - AT
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