Settlement application eligibility requires a pending assessment when filed, preventing an extra prior-eligibility condition from blocking considerati...
Reassessment for unreturned property sales survives where transfer information, non-filing, and unsupported exemption claims establish a prima facie l...
Profit-element taxation limits additions for unaccounted flat-sale receipts and grey-market purchases, while reliable search records support partial a...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
