Transaction value rejection requires reliable corroboration; refundable VAT is excluded and temporary registration does not defeat new-vehicle exempti...
Appellate jurisdiction remains available where a wrist-worn gold ornament cannot conclusively be characterised as imported baggage at the preliminary ...
Written complaint requirement bars cognizance on police reports for securities offences, while unsupported breach of trust and cheating allegations fa...
Accrual of income in India - PE in India or not? - use or right to use brand name/trade mark - the receipts cannot be treated as royalty under Article 12(3)(a) of the Tax Treaty. Similarly, the fee received cannot be treated as royalty under Article 12(3)(b) as there is no transfer of use or right to use any industrial or commercial or scientific equipments. In any case of the matter, the fees received are purely for certain services, therefore, in our view, they cannot be treated as royalty. - AT
Accrual of income in India - PE in India or not? - use or right to use brand name/trade mark - the receipts cannot be treated as royalty under Article 12(3)(a) of the Tax Treaty. Similarly, the fee received cannot be treated as royalty under Article 12(3)(b) as there is no transfer of use or right to use any industrial or commercial or scientific equipments. In any case of the matter, the fees received are purely for certain services, therefore, in our view, they cannot be treated as royalty. - AT
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