Fair-rent assessment requires consideration of lease terms, valuation principles and prevailing market rent; the certificate was quashed for fresh rev...
Document Identification Number compliance is satisfied when electronically communicated orders are promptly authenticated through a correctly identifi...
Industrial shrimp-feed machinery classification follows its commercial function, placing integrated production plants under the specific industrial fo...
The key points in the legal document are: Software licensing amounts do not qualify as Fees for Included Services under Article 12(4)(b) of the India-US DTAA, as the 'make available' clause is not satisfied. The non-resident has not made available the technical skill, expertise, or technical know-how used in preparing the commercial information to the assessee. Installation and integration services related to software are merely support services and cannot be taxed as Fees for Included Services when the primary services are not taxable. The assessee's appeal is allowed, following relevant precedents.
The key points in the legal document are: Software licensing amounts do not qualify as Fees for Included Services under Article 12(4)(b) of the India-US DTAA, as the 'make available' clause is not satisfied. The non-resident has not made available the technical skill, expertise, or technical know-how used in preparing the commercial information to the assessee. Installation and integration services related to software are merely support services and cannot be taxed as Fees for Included Services when the primary services are not taxable. The assessee's appeal is allowed, following relevant precedents.
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