Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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The ITAT Delhi held that Bandwidth charges received by a non-resident corporate entity from India are not taxable as royalty income u/s 9(1)(vi) and Article 12(3) of India-Singapore DTAA. The Tribunal relied on its consistent view in prior assessment years and directed the AO to delete the addition. Additionally, the ITAT directed the AO to grant TDS credit for corresponding TDS deducted on interest income from an income tax refund, as claimed by the assessee.
The ITAT Delhi held that Bandwidth charges received by a non-resident corporate entity from India are not taxable as royalty income u/s 9(1)(vi) and Article 12(3) of India-Singapore DTAA. The Tribunal relied on its consistent view in prior assessment years and directed the AO to delete the addition. Additionally, the ITAT directed the AO to grant TDS credit for corresponding TDS deducted on interest income from an income tax refund, as claimed by the assessee.
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