Courier transshipment of imported goods via named carrier to air cargo stations renewed until 30.01.2026; exemption conditional, strict controls apply...
Insurer's investment gains and investment write-downs face Section 263 revision; enquiry upheld, Rule 5(b)(ii) lapse sustained, late corrigendum quash...
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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