Petition dismissed; petitioner allowed to submit detailed disclosures and documents for re-consideration; notices for 2019-23 may be adjudicated on me...
Confiscation and duty recovery quashed where licensing records show export obligation discharged; customs lacks jurisdiction absent licence annulment ...
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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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