Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
Specified income tax exemption for pollution control body remains conditional on non-commercial activity, unchanged income character, and return filin...
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ITAT ruled in favor of the assessee, determining tax liability for services provided to Indian customers under India-USA DTAA. The tribunal held that income from domain name registration services is not taxable in India under section 9(1)(vi) or Article 12(3). Additionally, non-domain services like web hosting and web designing do not constitute technical knowledge transfer and thus fall outside the scope of Fees for Independent Services (FIS) under Article 12(4)(b). The assessee qualifies as a resident under Article 4 of the treaty and is entitled to avail DTAA benefits, with the fundamental power to tax distinguished from actual tax payment.
ITAT ruled in favor of the assessee, determining tax liability for services provided to Indian customers under India-USA DTAA. The tribunal held that income from domain name registration services is not taxable in India under section 9(1)(vi) or Article 12(3). Additionally, non-domain services like web hosting and web designing do not constitute technical knowledge transfer and thus fall outside the scope of Fees for Independent Services (FIS) under Article 12(4)(b). The assessee qualifies as a resident under Article 4 of the treaty and is entitled to avail DTAA benefits, with the fundamental power to tax distinguished from actual tax payment.
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