Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
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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