Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Objective characteristics govern magnesium bis-glycinate chelate classification as an amino-acid coordination compound, not a food preparation or anti...
Independent professional certification requires pleaded knowledge or complicity for criminal liability; untimely complaints remain barred by limitatio...
Accrual of income in India - Royalty receipts - taxation of revenue from online database of text journal and books as royalty income u/Article 12 of India US DTAA - The Tribunal concluded that since there was no transfer of legal title in the copyrighted article, and the users did not acquire any right to exploit the underlying copyright, the revenue derived from granting access to the database did not constitute royalty under Article 12 of the agreement.
Accrual of income in India - Royalty receipts - taxation of revenue from online database of text journal and books as royalty income u/Article 12 of India US DTAA - The Tribunal concluded that since there was no transfer of legal title in the copyrighted article, and the users did not acquire any right to exploit the underlying copyright, the revenue derived from granting access to the database did not constitute royalty under Article 12 of the agreement.
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