Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
Toy balloon tariff classification: functional heading prevails over residual rubber and festive article headings, supporting penalties for deliberate ...
Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent...
Foreign customs declarations and importer admissions established undervaluation, supporting sequential value redetermination, differential duty, and 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.
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