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...
Income deemed to accrue or arise in India - FTS/FIS - receipts pertaining to supply of software (including AMC services) - The tribunal confirmed that software licensing fees received by a U.S.-based company from an Indian entity do not constitute royalty but are instead business income, non-taxable in India due to the absence of a permanent establishment. Similarly, the AMC charges, closely tied to the software licensing, also do not meet the DTAA criteria for FTS as they do not make available any substantive technical knowledge or skills.
Income deemed to accrue or arise in India - FTS/FIS - receipts pertaining to supply of software (including AMC services) - The tribunal confirmed that software licensing fees received by a U.S.-based company from an Indian entity do not constitute royalty but are instead business income, non-taxable in India due to the absence of a permanent establishment. Similarly, the AMC charges, closely tied to the software licensing, also do not meet the DTAA criteria for FTS as they do not make available any substantive technical knowledge or skills.
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