Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Development rights transfers treated as immovable property, while construction abatement applies and repeated non-payment permits extended service-tax...
Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
The ITAT, an Appellate Tribunal, addressed the issue of whether income deemed to accrue or arise in India through royalty and fees for technical support services. The tribunal analyzed the "make available" clause in the India-USA DTAA and determined that the services provided were customized and differentiated, not constituting royalty. Referring to a Supreme Court decision, it was held that payments to non-resident vendors for technical support were not taxable as royalty under the DTAA. Consequently, revenue from cloud-based services subscriptions was deemed non-taxable under the India-US DTAA. The decision favored the assessee in this case.
The ITAT, an Appellate Tribunal, addressed the issue of whether income deemed to accrue or arise in India through royalty and fees for technical support services. The tribunal analyzed the "make available" clause in the India-USA DTAA and determined that the services provided were customized and differentiated, not constituting royalty. Referring to a Supreme Court decision, it was held that payments to non-resident vendors for technical support were not taxable as royalty under the DTAA. Consequently, revenue from cloud-based services subscriptions was deemed non-taxable under the India-US DTAA. The decision favored the assessee in this case.
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