PMLA anticipatory bail requires satisfaction of twin conditions, while predicate-offence protection does not extend to independent money-laundering pr...
School-affiliation charges remain taxable where not directly connected with examinations, while extended limitation requires proof of deliberate tax e...
Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
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The ITAT, with the Third Member concurring with the Judicial Member, held that payments by the assessee for use of IT infrastructure facilities do not constitute "plant" and therefore do not fall within the scope of Article 12(3)(a) of the Indo-Belgium DTAA; absent the specific phrase "for the use of, or right to use, industrial, commercial or scientific equipment," such payments are not taxable as royalties under section 9(1)(vi) of the Act for the year in question. Consequently, no TDS liability arises on those payments and the assessee's appeal is allowed.
The ITAT, with the Third Member concurring with the Judicial Member, held that payments by the assessee for use of IT infrastructure facilities do not constitute "plant" and therefore do not fall within the scope of Article 12(3)(a) of the Indo-Belgium DTAA; absent the specific phrase "for the use of, or right to use, industrial, commercial or scientific equipment," such payments are not taxable as royalties under section 9(1)(vi) of the Act for the year in question. Consequently, no TDS liability arises on those payments and the assessee's appeal is allowed.
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