Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
Diagnostic microcuvette classification follows sole-use analytical function, placing specialised disposable cuvettes with their analyser rather than g...
Customs Broker licensing proceedings fail when their offence-report foundation collapses and authorisation, advisory, and KYC duties remain unbreached...
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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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