Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The ITAT affirmed that amounts paid for borrowed services do not constitute fees for technical services (FTS) under Article 12 of the India-Singapore DTAA for AY 2020-21 and AY 2021-22. Relying on a Co-ordinate Bench decision in the assessee's own earlier years and noting the Departmental Representative's failure to controvert identical facts, the Tribunal concluded such receipts are not taxable as income deemed to accrue or arise in India under the DTAA. The appeal was allowed in favour of the assessee and decided against the revenue, with relief limited to the specified assessment years.
The ITAT affirmed that amounts paid for borrowed services do not constitute fees for technical services (FTS) under Article 12 of the India-Singapore DTAA for AY 2020-21 and AY 2021-22. Relying on a Co-ordinate Bench decision in the assessee's own earlier years and noting the Departmental Representative's failure to controvert identical facts, the Tribunal concluded such receipts are not taxable as income deemed to accrue or arise in India under the DTAA. The appeal was allowed in favour of the assessee and decided against the revenue, with relief limited to the specified assessment years.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
