Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
Non-resident corporate assessee's receipts for maintenance, support, training services, and additional services relating to software migration held not taxable as Fees for Technical Services (FTS) under India-Singapore DTAA. Services did not make available technical knowledge or skills to recipient on a recurring basis. Assessee had no PE in India, so business receipts not taxable. ITAT allowed assessee's appeal.
Non-resident corporate assessee's receipts for maintenance, support, training services, and additional services relating to software migration held not taxable as Fees for Technical Services (FTS) under India-Singapore DTAA. Services did not make available technical knowledge or skills to recipient on a recurring basis. Assessee had no PE in India, so business receipts not taxable. ITAT allowed assessee's appeal.
Note: It is a system-generated summary and is for quick reference only.
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