Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Income deemed to accrue or arise in India - treatment of "Commission income" and receipts from "Subscription fee" - Assessee in publishing business receiving "Subscription fee" from Indian customers on behalf of affiliated publishers, revenue treated as Fees for Technical Services (FTS). Held: Services did not involve application of special skill or technical knowledge, merely promotion, sale, distribution of publications or support services. No special skills required for services under Commissionaire Agreement. Services not categorized as technical or consultancy services. Subscription amount not royalty as no copyright granted to subscribers, only copyrighted publication sold. Assessee's contention upheld, services not FTS. Decided in favor of assessee.
Income deemed to accrue or arise in India - treatment of "Commission income" and receipts from "Subscription fee" - Assessee in publishing business receiving "Subscription fee" from Indian customers on behalf of affiliated publishers, revenue treated as Fees for Technical Services (FTS). Held: Services did not involve application of special skill or technical knowledge, merely promotion, sale, distribution of publications or support services. No special skills required for services under Commissionaire Agreement. Services not categorized as technical or consultancy services. Subscription amount not royalty as no copyright granted to subscribers, only copyrighted publication sold. Assessee's contention upheld, services not FTS. Decided in favor of assessee.
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