Faceless assessment and registration procedures are updated through electronic communication, revised recovery rules, extended deadlines, and replacem...
Risk-based selective vessel boarding requires accurate declarations and preserves master and agent liability where physical inspections are not select...
Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
The SC dismissed the SLP challenging the ITAT's decision that DTAA benefits apply in proceedings under section 201 of the Act, affirming that payments made to a foreign entity for interconnectivity charges do not constitute royalty, FTS, or business profits taxable in India. The court held that as the facilities are located outside India and the agreement is with a Belgium entity lacking Indian presence, Indian tax authorities lack jurisdiction to tax income from extraterritorial sources. The assessee is not required to perform the impossible by disregarding DTAA provisions. Pending applications were disposed of accordingly.
The SC dismissed the SLP challenging the ITAT's decision that DTAA benefits apply in proceedings under section 201 of the Act, affirming that payments made to a foreign entity for interconnectivity charges do not constitute royalty, FTS, or business profits taxable in India. The court held that as the facilities are located outside India and the agreement is with a Belgium entity lacking Indian presence, Indian tax authorities lack jurisdiction to tax income from extraterritorial sources. The assessee is not required to perform the impossible by disregarding DTAA provisions. Pending applications were disposed of accordingly.
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TaxTMI 
TaxTMI 
