Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
Income deemed to accrue or arise in India - revenue earned by the assessee from the provisions of transmission services of voice, data and programmes of space segment capacity on Satellites to customers - AO held it in the nature of “Royalty” u/s 9(1)(vi) of the Income Tax Act and Article 12(4) of the India-Netherland DTAA - The ITAT, while deleting the additions, held that, it is fallacious to assume that any change made to domestic law to rectify a situation of mistaken interpretation can spontaneously further their case in an international treaty. Therefore, mere amendment to Section 9(1)(vi) cannot result in a change.
Income deemed to accrue or arise in India - revenue earned by the assessee from the provisions of transmission services of voice, data and programmes of space segment capacity on Satellites to customers - AO held it in the nature of “Royalty” u/s 9(1)(vi) of the Income Tax Act and Article 12(4) of the India-Netherland DTAA - The ITAT, while deleting the additions, held that, it is fallacious to assume that any change made to domestic law to rectify a situation of mistaken interpretation can spontaneously further their case in an international treaty. Therefore, mere amendment to Section 9(1)(vi) cannot result in a change.
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