Unlawful outward remittances via Hawala using proforma invoices and electronic records proved; documents admitted, directors penalised, penalties redu...
Attachment of equivalent-value properties as proceeds of crime upheld; preventive attachment order and confirmation sustained; no independent ED reinv...
Broker trading-system "technical glitch" redefinition and narrowed incident-reporting regime for large IBT/STWT brokers requiring 2-hr notice and 14-w...
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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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