Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
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The income deemed to accrue or arise in India, including reimbursement received for SAP Software and Microsoft License fees, was held to be taxable as royalty receipts u/s 9(1)(vi) and Article 12 of the Double Taxation Avoidance Agreement (DTAA). The Dispute Resolution Panel (DRP) directed the Assessing Officer (AO) to examine the taxability of Information & Communication Technology Service Charges (ICT Service Charges) received from PVM India as Fees for Technical Services (FTS) under Article 12 of the DTAA. The Tribunal's decision in the assessee's own case for the previous year was limited to examining the factual aspects of the agreements and the nature of services in the context of the 'make available' clause introduced by the amendment dated 30.08.1999 in the India-Netherlands DTAA. The issue was restored to the AO to re-examine in light of the Tribunal's observations regarding the restricted scope of the 'make available' clause.
The income deemed to accrue or arise in India, including reimbursement received for SAP Software and Microsoft License fees, was held to be taxable as royalty receipts u/s 9(1)(vi) and Article 12 of the Double Taxation Avoidance Agreement (DTAA). The Dispute Resolution Panel (DRP) directed the Assessing Officer (AO) to examine the taxability of Information & Communication Technology Service Charges (ICT Service Charges) received from PVM India as Fees for Technical Services (FTS) under Article 12 of the DTAA. The Tribunal's decision in the assessee's own case for the previous year was limited to examining the factual aspects of the agreements and the nature of services in the context of the 'make available' clause introduced by the amendment dated 30.08.1999 in the India-Netherlands DTAA. The issue was restored to the AO to re-examine in light of the Tribunal's observations regarding the restricted scope of the 'make available' clause.
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