Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
Royalty - Taxability of Management Service Fees (MSF) - For rendering of these services, there is no element of imparting any "know how or there is transfer of any knowledge, skill or experience. Thus, we hold that none of the services provided by the assessee in the term of "service agreement" falls within the scope and ambit of "royalty" as defined in Article 12(4) of the DTAA. - AT
Royalty - Taxability of Management Service Fees (MSF) - For rendering of these services, there is no element of imparting any "know how or there is transfer of any knowledge, skill or experience. Thus, we hold that none of the services provided by the assessee in the term of "service agreement" falls within the scope and ambit of "royalty" as defined in Article 12(4) of the DTAA. - AT
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