Opportunity to respond to jurisdictional reports is mandatory before customs settlement duty enhancement; connected applications require consistent ad...
Specific customs headings for scaffolding components prevail over general classification, invalidating misclassification proceedings and enabling with...
Liquidator appointment under Section 34 requires consideration of creditor recommendations, valid professional authorisation, and preservation of vali...
Income-tax exemption for specified regulatory fees and government grants applies subject to non-commercial activity and continuing compliance conditio...
Digital accessibility audit and remediation deadlines extended, while all other disability-compliance obligations for regulated entities remain unchan...
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The ITAT addressed TDS u/s 195 withholding tax demand by the AO on foreign remittances for clinical trials, consultancy, and market surveys. The "make available" clause in tax treaties was interpreted. The ITAT found in favor of the assessee for remittances to USA-Canada parties and payments for science data base access, as they did not constitute royalty. Payment to Cambridgesoft for software purchase was not considered royalty. For fees paid to Thailand companies, no specific provision existed in the India-Thailand tax treaty, and since the companies had no permanent establishments in India, the income was not taxable in India. Payment to a Sri Lanka-based party for market survey was not considered technical services under section 9(1)(vii) of the Act. The CIT(A)'s decision to delete the demand was upheld, and the revenue's appeal was dismissed.
The ITAT addressed TDS u/s 195 withholding tax demand by the AO on foreign remittances for clinical trials, consultancy, and market surveys. The "make available" clause in tax treaties was interpreted. The ITAT found in favor of the assessee for remittances to USA-Canada parties and payments for science data base access, as they did not constitute royalty. Payment to Cambridgesoft for software purchase was not considered royalty. For fees paid to Thailand companies, no specific provision existed in the India-Thailand tax treaty, and since the companies had no permanent establishments in India, the income was not taxable in India. Payment to a Sri Lanka-based party for market survey was not considered technical services under section 9(1)(vii) of the Act. The CIT(A)'s decision to delete the demand was upheld, and the revenue's appeal was dismissed.
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