Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
Specified income tax exemption for pollution control body remains conditional on non-commercial activity, unchanged income character, and return filin...
Jurisdictional facts in certificate-of-origin discrepancies can support customs show-cause proceedings, leaving factual explanations for departmental ...
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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