Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
ITAT adjudicated a dispute regarding Fees for Technical Services (FTS) in cross-border logistics services. The tribunal comprehensively analyzed the nature of services, emphasizing that FTS requires specialized knowledge transfer beyond mere service provision. The court distinguished between standard regulatory compliance and genuine technical expertise. Crucially, the tribunal determined that generic operational instructions, customs clearance procedures, and workforce standardization do not constitute FTS. The software development aspect was referenced with precedential principles from Supreme Court jurisprudence. Ultimately, the appellate tribunal allowed the assessee's appeal, rejecting the revenue department's contention of taxable FTS, thereby narrowing the interpretation of technical services under domestic tax regulations and bilateral tax treaty frameworks.
ITAT adjudicated a dispute regarding Fees for Technical Services (FTS) in cross-border logistics services. The tribunal comprehensively analyzed the nature of services, emphasizing that FTS requires specialized knowledge transfer beyond mere service provision. The court distinguished between standard regulatory compliance and genuine technical expertise. Crucially, the tribunal determined that generic operational instructions, customs clearance procedures, and workforce standardization do not constitute FTS. The software development aspect was referenced with precedential principles from Supreme Court jurisprudence. Ultimately, the appellate tribunal allowed the assessee's appeal, rejecting the revenue department's contention of taxable FTS, thereby narrowing the interpretation of technical services under domestic tax regulations and bilateral tax treaty frameworks.
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