Educational approval requires mandatory State registration, but incidental surplus and trustee-owned land do not prove private benefit or profit motiv...
Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Page of 4826
Press 'Enter' after typing page number.
381 to 400 of 96510 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Entitlement to Nil/lower rate withholding tax certificate u/s 197 - Absence of a Permanent Establishment (PE). - The High Court found that the assistance and training provided by SFDC Ireland were ancillary to the sale of its products and did not constitute the provision of technical services as defined under the DTAA. - The judgment clarified that the payments made to SFDC Ireland were for the purchase of software products for resale by SFDC India and not for the provision of technical services. The court emphasized that the technical support and training offered were related to the usage of these products and did not amount to FTS. - Matter restored back for fresh consideration.
Entitlement to Nil/lower rate withholding tax certificate u/s 197 - Absence of a Permanent Establishment (PE). - The High Court found that the assistance and training provided by SFDC Ireland were ancillary to the sale of its products and did not constitute the provision of technical services as defined under the DTAA. - The judgment clarified that the payments made to SFDC Ireland were for the purchase of software products for resale by SFDC India and not for the provision of technical services. The court emphasized that the technical support and training offered were related to the usage of these products and did not amount to FTS. - Matter restored back for fresh consideration.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4826 
Join Channel 
