Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
Customs relief for Strait of Hormuz maritime disruptions remains available, with existing conditions continuing unchanged through the extended validit...
Challenge AAR ruling - Income taxable in India or not? - TDS liability u/s 195 - whether payments to SIPCL for BSS under the Cost Contribution Arrangement ("CCA") - The High Court determined the services availed to be managerial, not technical or consultancy that "make available" technical knowledge, skill, or processes as required by Article 13 of the DTAA. - The High Court found the AAR's interpretation flawed, emphasizing that the services in question did not satisfy the criteria of "making available" technical knowledge as per the DTAA. Consequently, it set aside the AAR's order mandating tax withholding under section 195 of the Income Tax Act, 1961.
Challenge AAR ruling - Income taxable in India or not? - TDS liability u/s 195 - whether payments to SIPCL for BSS under the Cost Contribution Arrangement ("CCA") - The High Court determined the services availed to be managerial, not technical or consultancy that "make available" technical knowledge, skill, or processes as required by Article 13 of the DTAA. - The High Court found the AAR's interpretation flawed, emphasizing that the services in question did not satisfy the criteria of "making available" technical knowledge as per the DTAA. Consequently, it set aside the AAR's order mandating tax withholding under section 195 of the Income Tax Act, 1961.
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