Interactive flat panels meeting automatic data processing conditions are distinguished from monitors, while later classification clarifications apply ...
Statutory transfer formalities invalidated alleged share and property transfers, while retrospective record manipulation constituted oppression and mi...
Provisional attachment of laundered funds and equivalent-value property sustained, with statutory protection limited to pension, gratuity and providen...
The Appellate Tribunal (ITAT) examined the taxability of sales commission as Fees for Technical Services (FTS) under the Act and India-USA DTAA. The Tribunal held that the sales commission received did not meet the definition of "FTS" under both the Act and the DTAA. It was noted that since the payer was previously held exempt from tax on commission payments, the same applies to the recipient. Ground No.3 was allowed in favor of the assessee, determining that sales commission is not taxable.
The Appellate Tribunal (ITAT) examined the taxability of sales commission as Fees for Technical Services (FTS) under the Act and India-USA DTAA. The Tribunal held that the sales commission received did not meet the definition of "FTS" under both the Act and the DTAA. It was noted that since the payer was previously held exempt from tax on commission payments, the same applies to the recipient. Ground No.3 was allowed in favor of the assessee, determining that sales commission is not taxable.
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