Blocked input tax credit for resort construction remains unavailable; interest follows actual utilisation, while delayed payment attracts statutory pe...
Duplicate PAN allocation requires record verification and deactivation reasons before assessment-related transactions can be attributed to an assessee...
Faceless assessment safeguards require requested personal hearings and adequate final show-cause response time, failing which reassessment is required...
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Income deemed to accrue or arise in India - Payments received by the assessee from it Indian customers on account of Centralized Services - Fee for Technical Services as defined u/s 9(1)(vii) of the Income Tax Act, 1961 or “Fee for included Services as defined u/Article 12(4)(a) of the India-US DTAA - The Appellate Tribunal, after considering the submissions and precedents, upheld the decision of the CIT(A), agreeing that the payments received by the assessee were not in the nature of FTS under the Income Tax Act or the DTAA. The Tribunal noted that the issue was squarely covered in favor of the assessee by its own past cases and the rulings of the Hon'ble Delhi High Court.
Income deemed to accrue or arise in India - Payments received by the assessee from it Indian customers on account of Centralized Services - Fee for Technical Services as defined u/s 9(1)(vii) of the Income Tax Act, 1961 or “Fee for included Services as defined u/Article 12(4)(a) of the India-US DTAA - The Appellate Tribunal, after considering the submissions and precedents, upheld the decision of the CIT(A), agreeing that the payments received by the assessee were not in the nature of FTS under the Income Tax Act or the DTAA. The Tribunal noted that the issue was squarely covered in favor of the assessee by its own past cases and the rulings of the Hon'ble Delhi High Court.
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