Request-driven road restoration attracts reverse-charge GST, not governmental-function treatment or compensatory-damages status for business recipient...
Road restoration charges for commercial pipeline works are taxable Government services, with reverse charge liability and no public-function exemption...
Model-wise import cap monitoring cannot justify withholding used multifunction machines where all-India tracking is absent and full security is furnis...
ITAT ruled that service fees received were not taxable as Fees for Included Services (FIS) under Article 12(4)(b) of India-USA DTAA, consistent with previous treatment of consultancy and training fees in AY 2020-21. DRP findings remained identical across both assessment years. Interest under sections 234A and 234B to be levied as per law. AO directed to verify and allow TDS credit claims according to legal provisions. Regarding incorrect adjustment of refund recovery, AO instructed to examine assessee's claim and modify tax computation in accordance with law. Grounds 4 to 11 were allowed in favor of assessee.
ITAT ruled that service fees received were not taxable as Fees for Included Services (FIS) under Article 12(4)(b) of India-USA DTAA, consistent with previous treatment of consultancy and training fees in AY 2020-21. DRP findings remained identical across both assessment years. Interest under sections 234A and 234B to be levied as per law. AO directed to verify and allow TDS credit claims according to legal provisions. Regarding incorrect adjustment of refund recovery, AO instructed to examine assessee's claim and modify tax computation in accordance with law. Grounds 4 to 11 were allowed in favor of assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
