Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
The case pertains to taxability of income in India related to royalty and fees for technical services. The Appellate Tribunal held that license fees received by a company for granting trademark rights are taxable in India as business income u/s 9. The company entered into a Hotel Management Agreement, providing marketing and reservation services. Payments made for System Fund support services and SCHI Facility charges were held not to be Royalty/FTS and hence not taxable. The Tribunal directed the Assessing Officer to verify Travel Agent Commission receipts to determine if they are reimbursement in nature, in line with previous decisions. The Assessee can submit further details to support their claim.
The case pertains to taxability of income in India related to royalty and fees for technical services. The Appellate Tribunal held that license fees received by a company for granting trademark rights are taxable in India as business income u/s 9. The company entered into a Hotel Management Agreement, providing marketing and reservation services. Payments made for System Fund support services and SCHI Facility charges were held not to be Royalty/FTS and hence not taxable. The Tribunal directed the Assessing Officer to verify Travel Agent Commission receipts to determine if they are reimbursement in nature, in line with previous decisions. The Assessee can submit further details to support their claim.
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