Risk-based postal import clearance standardises electronic assessment, document requests, duty realisation and delivery controls at Foreign Post Offic...
Customs Cargo Service Provider appointment extends custodianship to additional terminal land, subject to cargo-control, security and licence condition...
Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
Clubbing of income of Non-resident and Permanent Establishment (PE) - Levy of surcharge at 5% as against assessee’s claim of 2% - The royalty and Fee for Technical Services (FTS) income of the assessee, a non-resident corporate entity, should not be clubbed with the income of the Permanent Establishment for the purpose of surcharge under domestic law, as it is governed under the India-Germany Double Taxation Avoidance Agreement (DTAA). - The DTAA specifies a maximum tax rate of 10% on such income, and the imposition of a higher surcharge would violate this agreement. - AT
Clubbing of income of Non-resident and Permanent Establishment (PE) - Levy of surcharge at 5% as against assessee’s claim of 2% - The royalty and Fee for Technical Services (FTS) income of the assessee, a non-resident corporate entity, should not be clubbed with the income of the Permanent Establishment for the purpose of surcharge under domestic law, as it is governed under the India-Germany Double Taxation Avoidance Agreement (DTAA). - The DTAA specifies a maximum tax rate of 10% on such income, and the imposition of a higher surcharge would violate this agreement. - AT
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