Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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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