Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
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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