Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
Scientific research association approval requires continuing SIRO status, annual donation reporting, and donor certificates for the approved foundatio...
Scientific research institution approval is conditional on SIRO recognition, annual donation reporting, donor certification, and prescribed compliance...
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Accrual of income in India - taxability of administrative fee received by the assessee as royalty - AO made the addition on the ground that the IMEI number is the unique invention to track the mobile devices - the ITAT held that the amount received by the assessee did not fall within the definition of royalty under section 9(1)(vi) of the Act or under Article 12(3) of the India-USA DTAA. The ITAT noted that the assessee provided a database of unique numbers, which, when combined with other numbers provided by mobile manufacturers, were implanted in mobile devices for tracking purposes. The ITAT emphasized that there was no transfer of rights to use any copyright, patent, or intellectual property associated with the numbers provided by the assessee.
Accrual of income in India - taxability of administrative fee received by the assessee as royalty - AO made the addition on the ground that the IMEI number is the unique invention to track the mobile devices - the ITAT held that the amount received by the assessee did not fall within the definition of royalty under section 9(1)(vi) of the Act or under Article 12(3) of the India-USA DTAA. The ITAT noted that the assessee provided a database of unique numbers, which, when combined with other numbers provided by mobile manufacturers, were implanted in mobile devices for tracking purposes. The ITAT emphasized that there was no transfer of rights to use any copyright, patent, or intellectual property associated with the numbers provided by the assessee.
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