Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
The ITAT examined royalty receipts from online chemistry databases and journal subscriptions, determining that the subscription revenues from CAS and PUBS divisions do not constitute taxable royalty under Section 9(1)(vi) and Article 12(3) of the India-USA DTAA. Relying on the assessee's previous case for the assessment year 2014-15, the tribunal upheld the assessee's plea and directed the deletion of the tax addition. The appellate tribunal ultimately allowed the assessee's appeal, ruling that the subscription income was not taxable as royalty in the assessee's hands.
The ITAT examined royalty receipts from online chemistry databases and journal subscriptions, determining that the subscription revenues from CAS and PUBS divisions do not constitute taxable royalty under Section 9(1)(vi) and Article 12(3) of the India-USA DTAA. Relying on the assessee's previous case for the assessment year 2014-15, the tribunal upheld the assessee's plea and directed the deletion of the tax addition. The appellate tribunal ultimately allowed the assessee's appeal, ruling that the subscription income was not taxable as royalty in the assessee's hands.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
