Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
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.
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