Toy balloon tariff classification: functional heading prevails over residual rubber and festive article headings, supporting penalties for deliberate ...
Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent...
Foreign customs declarations and importer admissions established undervaluation, supporting sequential value redetermination, differential duty, and m...
Customs seizure safeguards prevent detention-based limitation avoidance and invalidate provisional release conditions for imported vehicles under an i...
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ITAT held in favour of the appellant that amounts received for rendering IT support and non-IT services are not taxable as Fee for Technical Services/Fee for Included Services under the Act or the India-UK DTAA for purposes of TDS u/s 195. The Tribunal affirmed the DRP's factual finding that "IT support" and "IT development" services were dissimilar and found no reliable evidence that technical knowledge, skill or know-how was made available to the associated enterprise in India or that the assessee enabled the AE to perform the services independently. Consequently the additions treating receipts as FTS/FIS were deleted and both grounds of appeal were allowed.
ITAT held in favour of the appellant that amounts received for rendering IT support and non-IT services are not taxable as Fee for Technical Services/Fee for Included Services under the Act or the India-UK DTAA for purposes of TDS u/s 195. The Tribunal affirmed the DRP's factual finding that "IT support" and "IT development" services were dissimilar and found no reliable evidence that technical knowledge, skill or know-how was made available to the associated enterprise in India or that the assessee enabled the AE to perform the services independently. Consequently the additions treating receipts as FTS/FIS were deleted and both grounds of appeal were allowed.
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