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...
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.
TaxTMI 
TaxTMI 
of 4915 
