Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
The ITAT held that the appellant, being a domain name registrar, does not own the domain names it helps register and cannot confer the right to use or transfer such domain names. Therefore, the income earned from domain name registration services is not taxable as royalty u/s 9(1)(vi) of the Act and Article 12(3)(a) of the India-USA DTAA. The ITAT affirmed the Delhi HC's decision in the appellant's own case for earlier years. Regarding treaty benefits, the ITAT held that the appellant, being an LLP, is eligible for benefits under the DTAA, relying on precedents. The income from non-domain services like web hosting and web designing does not involve transfer of technical knowledge or know-how and hence cannot be taxed as fees for included services under Article 12(4)(b) of the DTAA.
The ITAT held that the appellant, being a domain name registrar, does not own the domain names it helps register and cannot confer the right to use or transfer such domain names. Therefore, the income earned from domain name registration services is not taxable as royalty u/s 9(1)(vi) of the Act and Article 12(3)(a) of the India-USA DTAA. The ITAT affirmed the Delhi HC's decision in the appellant's own case for earlier years. Regarding treaty benefits, the ITAT held that the appellant, being an LLP, is eligible for benefits under the DTAA, relying on precedents. The income from non-domain services like web hosting and web designing does not involve transfer of technical knowledge or know-how and hence cannot be taxed as fees for included services under Article 12(4)(b) of the DTAA.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
