Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter...
Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Page of 4782
Press 'Enter' after typing page number.
561 to 580 of 95636 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4782
Join Channel
TaxTMI 
