Investigation deposits refunded after failed customs demands fall outside the statutory appellate pre-deposit interest regime and may attract compensa...
Resolution plan finality extinguishes unquantified operational-creditor claims and pending proceedings unless the approved plan expressly preserves th...
Stakeholder-list modification permits liquidators to update entries on new information, subject to notifying the Adjudicating Authority within prescri...
TDS u/s 195 - liability u/s 201 and 201(1A) - Fees for Technical Services (FTS) or not - Distribution Agreement between the assessee and the foreign company - The Tribunal examined the terms of the agreements between the parties and concluded that the payments made were not in the nature of FTS. It highlighted that the agreements primarily involved the sale of integrated systems (including hardware and software) rather than the transfer of technical knowledge or expertise. - The ITAT noted that while some technical support was provided, it did not constitute the transfer of technical know-how or expertise. - The Tribunal upheld the applicability of the DTAA between India and the UK.
TDS u/s 195 - liability u/s 201 and 201(1A) - Fees for Technical Services (FTS) or not - Distribution Agreement between the assessee and the foreign company - The Tribunal examined the terms of the agreements between the parties and concluded that the payments made were not in the nature of FTS. It highlighted that the agreements primarily involved the sale of integrated systems (including hardware and software) rather than the transfer of technical knowledge or expertise. - The ITAT noted that while some technical support was provided, it did not constitute the transfer of technical know-how or expertise. - The Tribunal upheld the applicability of the DTAA between India and the UK.
Note: It is a system-generated summary and is for quick reference only.