Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
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...
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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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