Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
Reassessment against a deceased assessee: procedural defect mandates fresh reassessment; nonresponsive petitioner may be treated as legal representati...
The dominant issue was whether receipts from bandwidth charges earned by a Singapore-resident company were taxable in India as "royalty" under section 9(1)(vi) or as royalty under Article 12(3) of the India-Singapore DTAA. Following the binding precedent in the taxpayer's own case for earlier years, the tribunal held that bandwidth charges do not constitute consideration for the use of, or right to use, any copyright, process, or equipment so as to fall within the statutory or treaty definition of royalty. Consequently, the addition treating such receipts as royalty was directed to be deleted. - ITAT
The dominant issue was whether receipts from bandwidth charges earned by a Singapore-resident company were taxable in India as "royalty" under section 9(1)(vi) or as royalty under Article 12(3) of the India-Singapore DTAA. Following the binding precedent in the taxpayer's own case for earlier years, the tribunal held that bandwidth charges do not constitute consideration for the use of, or right to use, any copyright, process, or equipment so as to fall within the statutory or treaty definition of royalty. Consequently, the addition treating such receipts as royalty was directed to be deleted. - ITAT
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