Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
ITAT held that cost allocations for SUN/SAP software, GST scoping, and IT service charges do not constitute royalty or Fees for Technical Services (FTS). The tribunal found these receipts do not involve transfer of technical knowledge, skill, or experience, and therefore cannot be taxed in India. Following precedent from Supreme Court's Engineering Analysis Centre of Excellence case, the tribunal directed the Assessing Officer to delete additions made towards these cost allocations, rejecting revenue's contentions that these payments qualify as taxable technical services or royalty under Article 13 of the tax treaty.
ITAT held that cost allocations for SUN/SAP software, GST scoping, and IT service charges do not constitute royalty or Fees for Technical Services (FTS). The tribunal found these receipts do not involve transfer of technical knowledge, skill, or experience, and therefore cannot be taxed in India. Following precedent from Supreme Court's Engineering Analysis Centre of Excellence case, the tribunal directed the Assessing Officer to delete additions made towards these cost allocations, rejecting revenue's contentions that these payments qualify as taxable technical services or royalty under Article 13 of the tax treaty.
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