Form 26AS evidence requires successor-entity accounting verification after business transfer, while invoice-supported related-party advertising expend...
Money-laundering judgment timing requires awaiting the scheduled-offence decision despite continuation of the underlying trial where outcomes directly...
Accredited investor eligibility expands through securities-market exposure, while alternative investment fund disputes require prescribed resolution a...
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ITAT determined that remittances for data management charges do not constitute taxable technical services under section 9(1)(vii)(b). The non-resident entity lacks permanent establishment in India. Referencing precedent, the tribunal held that technical services are only taxable when the recipient cannot independently apply the technical knowledge without the service provider's aid. The tribunal directed the Assessing Officer to grant appropriate TDS credit and recalculate refund figures in accordance with legal provisions, allowing the grounds for statistical purposes.
ITAT determined that remittances for data management charges do not constitute taxable technical services under section 9(1)(vii)(b). The non-resident entity lacks permanent establishment in India. Referencing precedent, the tribunal held that technical services are only taxable when the recipient cannot independently apply the technical knowledge without the service provider's aid. The tribunal directed the Assessing Officer to grant appropriate TDS credit and recalculate refund figures in accordance with legal provisions, allowing the grounds for statistical purposes.
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