Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
Alternative GST remedy permitted protective writ intervention for ex parte adjudication, preserving independent appellate review of input tax credit d...
Assessment against deceased sole proprietor requires proceedings against the legal representative, rendering prior assessment and appellate orders inv...
Residential waste collection classification under SAC 999423 defeats composite-supply exemption where facilitating goods are not transferred to the lo...
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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