Promissory note presumption of consideration survives blank-signature and income-tax non-disclosure objections when admissions and attesting evidence ...
Charitable registration cancellation: limitation and jurisdiction upheld, but withdrawal quashed under discontinued provisions for skill-development e...
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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