Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
The assessee earned income from professional services rendered in foreign countries like Japan, Nepal, and Singapore. The Income Tax Appellate Tribunal (ITAT) examined the provisions of Article 12 and Article 14 of the India-Japan Double Taxation Avoidance Agreement (DTAA) pertaining to Assessment Year 2017-18. It held that Article 12 of the DTAA provides that income from professional services or other independent activities would be taxable in the resident country, i.e., India. However, clause 4 of Article 12 excludes payments made to individuals for carrying out independent professional services referred to in Article 14 from the definition of 'fees for technical services.' The ITAT concluded that the Japanese tax authorities' decision to withhold taxes from payments made to the assessee by its Japanese clients cannot be considered unreasonable or incorrect. Consequently, the ITAT allowed the assessee's claim for deduction, deciding against the revenue authorities.
The assessee earned income from professional services rendered in foreign countries like Japan, Nepal, and Singapore. The Income Tax Appellate Tribunal (ITAT) examined the provisions of Article 12 and Article 14 of the India-Japan Double Taxation Avoidance Agreement (DTAA) pertaining to Assessment Year 2017-18. It held that Article 12 of the DTAA provides that income from professional services or other independent activities would be taxable in the resident country, i.e., India. However, clause 4 of Article 12 excludes payments made to individuals for carrying out independent professional services referred to in Article 14 from the definition of 'fees for technical services.' The ITAT concluded that the Japanese tax authorities' decision to withhold taxes from payments made to the assessee by its Japanese clients cannot be considered unreasonable or incorrect. Consequently, the ITAT allowed the assessee's claim for deduction, deciding against the revenue authorities.
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