Export obligation removed by notification, customs duty demand invalidated; penalties under s.112 and s.114AA quashed due to inadmissible s.108 statem...
Customs officers must wear and use department-issued body-worn cameras when clearing passenger baggage, with daily secure transfer and 30-day retentio...
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The ITAT affirmed the CIT(A) and allowed the appeal of the assessee, holding that amounts received under the Regional Service Agreement constitute business profits under Article 7 of the India-Singapore DTAA and not "royalty" under s.9(1)(vi)/Article 12. The Tribunal found no transfer or grant of a right to use intangible property, nor any imparting of a corpus of industrial, commercial or scientific experience; services were performed outside India by regional personnel and remunerated on a cost-sharing basis with no PE in India. Accordingly the AO's royalty addition was unsustainable and the receipts are not taxable in India; decision in favour of the assessee is affirmed.
The ITAT affirmed the CIT(A) and allowed the appeal of the assessee, holding that amounts received under the Regional Service Agreement constitute business profits under Article 7 of the India-Singapore DTAA and not "royalty" under s.9(1)(vi)/Article 12. The Tribunal found no transfer or grant of a right to use intangible property, nor any imparting of a corpus of industrial, commercial or scientific experience; services were performed outside India by regional personnel and remunerated on a cost-sharing basis with no PE in India. Accordingly the AO's royalty addition was unsustainable and the receipts are not taxable in India; decision in favour of the assessee is affirmed.
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