Handicraft job work receives concessional GST only for registered principals and predominantly handmade goods; commercial resin articles remain taxabl...
Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination b...
Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
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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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