Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
Authorised courier due diligence protects against penalties where declared exports conceal prohibited goods despite proper documentation and customs p...
Customs-controlled container movement now extends to DP World facilities, subject to segregation, inspections, reconciliation, and EXIM cargo priority...
Income deemed to accrue or arise in India - offshore supply of design and engineering inextricably linked with manufacturing and supply of equipment, not taxable as Fees for Technical Services (FTS) under domestic law or India-Austria tax treaty. Offshore supply closely linked to offshore supply of plant and equipment, cannot be segregated as basic nature and character identical. Onshore supervisory services taxable as business profits under tax treaty, not as FTS on gross basis. Receipts connected to Permanent Establishment (PE), to be taxed on net basis under Article 7. Certain other supervisory fees taxable as FTS under Article 12(4) of tax treaty, irrespective of PE. Reimbursement of expenses from Indian group companies for group information and business services not taxable as FTS, being cost sharing without profit element.
Income deemed to accrue or arise in India - offshore supply of design and engineering inextricably linked with manufacturing and supply of equipment, not taxable as Fees for Technical Services (FTS) under domestic law or India-Austria tax treaty. Offshore supply closely linked to offshore supply of plant and equipment, cannot be segregated as basic nature and character identical. Onshore supervisory services taxable as business profits under tax treaty, not as FTS on gross basis. Receipts connected to Permanent Establishment (PE), to be taxed on net basis under Article 7. Certain other supervisory fees taxable as FTS under Article 12(4) of tax treaty, irrespective of PE. Reimbursement of expenses from Indian group companies for group information and business services not taxable as FTS, being cost sharing without profit element.
Note: It is a system-generated summary and is for quick reference only.
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