Interactive flat panels meeting automatic data processing conditions are distinguished from monitors, while later classification clarifications apply ...
Statutory transfer formalities invalidated alleged share and property transfers, while retrospective record manipulation constituted oppression and mi...
Provisional attachment of laundered funds and equivalent-value property sustained, with statutory protection limited to pension, gratuity and providen...
Taxability of income in India - Taxability as Royalty or FTS - The tribunal systematically addressed the taxability of each type of service. It concluded that the services provided did not qualify as royalty or FTS under the India-Netherlands tax treaty because they did not make any technology, knowledge, experience, or skills "available" to the Indian group companies in such a manner that would enable them to perform these services independently in the future. The tribunal relied heavily on judicial precedents and the specific provisions of the India-Netherlands tax treaty, notably the "make available" clause.
Taxability of income in India - Taxability as Royalty or FTS - The tribunal systematically addressed the taxability of each type of service. It concluded that the services provided did not qualify as royalty or FTS under the India-Netherlands tax treaty because they did not make any technology, knowledge, experience, or skills "available" to the Indian group companies in such a manner that would enable them to perform these services independently in the future. The tribunal relied heavily on judicial precedents and the specific provisions of the India-Netherlands tax treaty, notably the "make available" clause.
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