Condonation of delay in filing GSTR-3B returns and entitlement to Section 62 benefit results in withdrawal of assessments and revocation of attachment...
Penalty for estimation of income and disallowances for tax non-deduction clarified: estimation-based penalties not sustainable; additions without conc...
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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