Service of notice and contractual debt acknowledgment preserved insolvency admission against a corporate guarantor despite limitation and natural just...
Original works exemption excludes standalone boulder transportation, leaving subcontracted railway-project transport services subject to service tax l...
Annual production capacity determinations excluding stenter galleries support refunds for unconstitutional excise levies without an unjust-enrichment ...
Vicarious liability for cheque dishonour requires specific allegations of responsibility and cheque signatory; generic director allegations cannot sus...
IT Resilience Index requires market infrastructure institutions to automate resilience scoring, early warnings, and continuous service-delivery monito...
ITAT affirmed deletion of an income addition and ruled in favour of the taxpayer, holding that reimbursements received from AEs for IT/support services constituted cost-to-cost allocations without profit and therefore did not constitute Fee for Included Services under the India-USA DTAA. The Tribunal found the "make-available" nexus absent because the services (desktop application training and routine IT administration) did not enable AEs to independently exploit any proprietary technology, and the AO failed to make requisite enquiries or rebut the taxpayer's factual record or the Master Inter-Company Services Agreement. Applying the coordinate bench precedent, the Tribunal concluded the AO's reliance on the taxpayer's own submissions was insufficient and deleted the addition.
ITAT affirmed deletion of an income addition and ruled in favour of the taxpayer, holding that reimbursements received from AEs for IT/support services constituted cost-to-cost allocations without profit and therefore did not constitute Fee for Included Services under the India-USA DTAA. The Tribunal found the "make-available" nexus absent because the services (desktop application training and routine IT administration) did not enable AEs to independently exploit any proprietary technology, and the AO failed to make requisite enquiries or rebut the taxpayer's factual record or the Master Inter-Company Services Agreement. Applying the coordinate bench precedent, the Tribunal concluded the AO's reliance on the taxpayer's own submissions was insufficient and deleted the addition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
