Independent manufacturing undertaking eligibility preserves Section 80IA/80IB deductions, while machinery kept ready for use qualifies for depreciatio...
Assessing Officer Satisfaction Requirement Bars Penalty for Cash Receipt in Immovable-Property Sale Cases Where Initiation Lacks Recorded Satisfaction...
Self-assessed import entries remain appealable, while bona fide classification disputes without misdeclaration cannot justify confiscation or penaltie...
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Income deemed to accrue or arise in India - payment made for providing interconnect services - The Tribunal found that the IUC charges do not fall under the definition of 'royalty' as per the DTAA between India and Sri Lanka. It noted that the services provided by the assessee do not permit use or right to use any intellectual property or process owned by the assessee. Moreover, the Tribunal observed that amendments to the Income Tax Act expanding the definition of 'royalty' cannot be read into the DTAA unless specifically amended. - The Tribunal allowed the appeal in favor of the assessee, ruling that the IUC charges received by the assessee are not taxable in India either under the Act or the DTAA provisions.
Income deemed to accrue or arise in India - payment made for providing interconnect services - The Tribunal found that the IUC charges do not fall under the definition of 'royalty' as per the DTAA between India and Sri Lanka. It noted that the services provided by the assessee do not permit use or right to use any intellectual property or process owned by the assessee. Moreover, the Tribunal observed that amendments to the Income Tax Act expanding the definition of 'royalty' cannot be read into the DTAA unless specifically amended. - The Tribunal allowed the appeal in favor of the assessee, ruling that the IUC charges received by the assessee are not taxable in India either under the Act or the DTAA provisions.
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