Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Accrual of income in India - royalty income - supply of software - absence of PE of the assessee in India - The Tribunal held that, the payments received by the assessee were for the supply of software, not for the use of the copyright or imparting information concerning industrial, commercial or scientific experience. As a result, the payments were not taxable as royalty income under the India-China Double Taxation Avoidance Agreement.
Accrual of income in India - royalty income - supply of software - absence of PE of the assessee in India - The Tribunal held that, the payments received by the assessee were for the supply of software, not for the use of the copyright or imparting information concerning industrial, commercial or scientific experience. As a result, the payments were not taxable as royalty income under the India-China Double Taxation Avoidance Agreement.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
