Service of notice and contractual debt acknowledgment preserved insolvency admission against a corporate guarantor despite limitation and natural just...
Original works exemption excludes standalone boulder transportation, leaving subcontracted railway-project transport services subject to service tax l...
Annual production capacity determinations excluding stenter galleries support refunds for unconstitutional excise levies without an unjust-enrichment ...
Vicarious liability for cheque dishonour requires specific allegations of responsibility and cheque signatory; generic director allegations cannot sus...
IT Resilience Index requires market infrastructure institutions to automate resilience scoring, early warnings, and continuous service-delivery monito...
ITAT held that reimbursements for SAP software installation, intranet, and maintenance charges are not taxable in India as 'Fees for Technical Services' under section 9(1)(vii) of the Income Tax Act. The tribunal directed the Assessing Officer to re-verify design and drawing details, placing the burden of proof on the assessee. Regarding interest chargeability for non-residents, the tribunal referenced precedent establishing that section 209(1) proviso has prospective effect only. Consequently, the tribunal deleted the disputed tax addition and accepted the assessee's grounds, maintaining judicial consistency with prior coordinate bench decisions from assessment year 1992-93 onwards.
ITAT held that reimbursements for SAP software installation, intranet, and maintenance charges are not taxable in India as 'Fees for Technical Services' under section 9(1)(vii) of the Income Tax Act. The tribunal directed the Assessing Officer to re-verify design and drawing details, placing the burden of proof on the assessee. Regarding interest chargeability for non-residents, the tribunal referenced precedent establishing that section 209(1) proviso has prospective effect only. Consequently, the tribunal deleted the disputed tax addition and accepted the assessee's grounds, maintaining judicial consistency with prior coordinate bench decisions from assessment year 1992-93 onwards.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
