Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
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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