Transaction value rejection requires reliable corroboration; refundable VAT is excluded and temporary registration does not defeat new-vehicle exempti...
Appellate jurisdiction remains available where a wrist-worn gold ornament cannot conclusively be characterised as imported baggage at the preliminary ...
Written complaint requirement bars cognizance on police reports for securities offences, while unsupported breach of trust and cheating allegations fa...
Risk-based postal import clearance standardises electronic assessment, document requests, duty realisation and delivery controls at Foreign Post Offic...
Customs Cargo Service Provider appointment extends custodianship to additional terminal land, subject to cargo-control, security and licence condition...
ITAT held that passenger system services provided by a US-based company to an Indian airline do not constitute Fees for Technical Services (FTS) under Article 12 of India-USA DTAA. The tribunal determined that no specific technology was made available to the Indian entity, and the services were rendered using standard software supported by the service provider's data center. Consequently, the tribunal upheld the CIT(A)'s order, finding the receipts non-taxable in India, effectively dismissing the revenue department's contentions regarding taxation under section 9(1)(vii) of the Income Tax Act as procedurally academic.
ITAT held that passenger system services provided by a US-based company to an Indian airline do not constitute Fees for Technical Services (FTS) under Article 12 of India-USA DTAA. The tribunal determined that no specific technology was made available to the Indian entity, and the services were rendered using standard software supported by the service provider's data center. Consequently, the tribunal upheld the CIT(A)'s order, finding the receipts non-taxable in India, effectively dismissing the revenue department's contentions regarding taxation under section 9(1)(vii) of the Income Tax Act as procedurally academic.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
