Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
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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