Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
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Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
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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