Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Income taxable in India or not - Business of supplying reservoir simulation software and related services. - Receipts from Indian customers - Taxing the entire receipts of the assessee by applying the provisions of section 44BB - The Tribunal agreed with the assessee that the absence of a PE in India was critical and thus Section 44BB of the Act was not applicable. The tribunal found that the impugned receipts could not be taxed as either royalties or FTS under the India-Canada DTAA because they did not meet the necessary criteria. It upheld the beneficial provisions of the DTAA over domestic tax laws, stating that the assessee could choose the more favorable treaty benefits.
Income taxable in India or not - Business of supplying reservoir simulation software and related services. - Receipts from Indian customers - Taxing the entire receipts of the assessee by applying the provisions of section 44BB - The Tribunal agreed with the assessee that the absence of a PE in India was critical and thus Section 44BB of the Act was not applicable. The tribunal found that the impugned receipts could not be taxed as either royalties or FTS under the India-Canada DTAA because they did not meet the necessary criteria. It upheld the beneficial provisions of the DTAA over domestic tax laws, stating that the assessee could choose the more favorable treaty benefits.
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