Request-driven road restoration attracts reverse-charge GST, not governmental-function treatment or compensatory-damages status for business recipient...
Road restoration charges for commercial pipeline works are taxable Government services, with reverse charge liability and no public-function exemption...
Model-wise import cap monitoring cannot justify withholding used multifunction machines where all-India tracking is absent and full security is furnis...
HC affirmed ITAT's ruling regarding income tax treatment of technical service fees from Indian customers. The court found no taxable technical service fees under India-USA DTAA or Section 9(1)(vii). Corporate allocation charges were deemed non-taxable as the assessee did not render direct services, transfer skills, or send employees to India. The court concluded that the ITAT's fact-specific findings were sound and no substantial legal question existed, effectively upholding the lower tribunal's assessment of non-taxability of the disputed income streams.
HC affirmed ITAT's ruling regarding income tax treatment of technical service fees from Indian customers. The court found no taxable technical service fees under India-USA DTAA or Section 9(1)(vii). Corporate allocation charges were deemed non-taxable as the assessee did not render direct services, transfer skills, or send employees to India. The court concluded that the ITAT's fact-specific findings were sound and no substantial legal question existed, effectively upholding the lower tribunal's assessment of non-taxability of the disputed income streams.
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TaxTMI 
TaxTMI 
of 4918 
