Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
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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