Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
Customs relief for Strait of Hormuz maritime disruptions remains available, with existing conditions continuing unchanged through the extended validit...
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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