Fraudulent import documents suspend limitation protection, while redemption of confiscated goods requires duty and interest despite bona fide purchase...
ODR arbitration participation remains mandatory after failed conciliation, while jurisdictional and maintainability objections stay available before t...
Transparency in technical bid evaluation requires disclosed standards and recorded reasons; opaque scoring invalidated tender awards and required fres...
Automated export obligation extensions remove separate regional applications after committee approval for Advance Authorisation and EPCG authorisation...
International cargo transhipment through Indian ports continues with Customs-controlled storage, re-export safeguards, and coordinated multi-station m...
Receipts from Indian customers for services provided outside India are not taxable u/s 9(1)(vi) of the Income Tax Act, 1961 read with Article 12 of the India-Singapore DTAA. Section 90 enables India to bring a tax treaty into force, and domestic law amendments cannot override treaty provisions. Treaty provisions supersede, and the assessee can opt for the more beneficial scheme u/s 90(2). Explanations inserted in Section 9 cannot override DTAA provisions. The transaction does not involve transfer or conferment of a right over a patent, invention or process. Customers availing services are not vested with a right over intellectual property or equipment. The word "process" in Section 9 must be construed ejusdem generis, referring to intellectual properties. Consideration is not taxable as royalty under Article 12 of the DTAA.
Receipts from Indian customers for services provided outside India are not taxable u/s 9(1)(vi) of the Income Tax Act, 1961 read with Article 12 of the India-Singapore DTAA. Section 90 enables India to bring a tax treaty into force, and domestic law amendments cannot override treaty provisions. Treaty provisions supersede, and the assessee can opt for the more beneficial scheme u/s 90(2). Explanations inserted in Section 9 cannot override DTAA provisions. The transaction does not involve transfer or conferment of a right over a patent, invention or process. Customers availing services are not vested with a right over intellectual property or equipment. The word "process" in Section 9 must be construed ejusdem generis, referring to intellectual properties. Consideration is not taxable as royalty under Article 12 of the DTAA.
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