Retrospective cancellation of charitable registration under section 12AB(4) was unsustainable; related-party benefit allegations did not prove nongenu...
Merger control notice and disclosure rules: Supreme Court limits penalties, rejects reopening of approved combination, and sets aside adverse findings...
Income deemed to accrue or arise in India - revenue characterization - Taxability of IUC [Interconnect utility charges] as Royalty u/s 9(1)(vi) - DTAA between India and Hongkong - The Tribunal noted that there is no treaty between India and Hong Kong, the country of which the assessee is a tax resident. The Tribunal held that the payments received by the assessee cannot be held to be royalty under section 9(1)(vi) of the Act. The revenue did not establish a permanent establishment of the assessee in India to tax the receipt in India. The payments received by the assessee are considered business profits taxable in the recipient country.
Income deemed to accrue or arise in India - revenue characterization - Taxability of IUC [Interconnect utility charges] as Royalty u/s 9(1)(vi) - DTAA between India and Hongkong - The Tribunal noted that there is no treaty between India and Hong Kong, the country of which the assessee is a tax resident. The Tribunal held that the payments received by the assessee cannot be held to be royalty under section 9(1)(vi) of the Act. The revenue did not establish a permanent establishment of the assessee in India to tax the receipt in India. The payments received by the assessee are considered business profits taxable in the recipient country.
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