Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
Fraudulent import documents suspend limitation protection, while redemption of confiscated goods requires duty and interest despite bona fide purchase...
ODR arbitration participation remains mandatory after failed conciliation, while jurisdictional and maintainability objections stay available before t...
Transparency in technical bid evaluation requires disclosed standards and recorded reasons; opaque scoring invalidated tender awards and required fres...
Automated export obligation extensions remove separate regional applications after committee approval for Advance Authorisation and EPCG authorisation...
International cargo transhipment through Indian ports continues with Customs-controlled storage, re-export safeguards, and coordinated multi-station m...
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 
