Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
ITAT adjudicated a tax dispute concerning technical services fees under Section 9(1)(vii) of the Income Tax Act and India-Netherlands Tax Treaty. The tribunal determined that the Department failed to establish the "make available" condition for Fees for Technical Services (FTS) across multiple service categories including recruitment, external information, corporate travel, health ecotox, and IT services. Consequently, the tribunal ruled that these services do not qualify as FTS under the India-Netherlands tax treaty, effectively finding in favor of the taxpayer by negating the tax liability for the specified technical service fees.
ITAT adjudicated a tax dispute concerning technical services fees under Section 9(1)(vii) of the Income Tax Act and India-Netherlands Tax Treaty. The tribunal determined that the Department failed to establish the "make available" condition for Fees for Technical Services (FTS) across multiple service categories including recruitment, external information, corporate travel, health ecotox, and IT services. Consequently, the tribunal ruled that these services do not qualify as FTS under the India-Netherlands tax treaty, effectively finding in favor of the taxpayer by negating the tax liability for the specified technical service fees.
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