Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
Receipts from providing in-flight entertainment content to an Indian airline were assessed as fees for technical services under section 9(1)(vii) and Article 13 of the India-UK DTAA. Applying Article 13(4)(c), the "make available" condition required the payer to receive technical knowledge, experience, skill, know-how, or processes enabling independent application. As the Revenue failed to establish any transfer of know-how or technical knowledge to the payer, the consideration for supplying content did not constitute FTS, rendering the corresponding addition unsustainable and warranting deletion. - ITAT
Receipts from providing in-flight entertainment content to an Indian airline were assessed as fees for technical services under section 9(1)(vii) and Article 13 of the India-UK DTAA. Applying Article 13(4)(c), the "make available" condition required the payer to receive technical knowledge, experience, skill, know-how, or processes enabling independent application. As the Revenue failed to establish any transfer of know-how or technical knowledge to the payer, the consideration for supplying content did not constitute FTS, rendering the corresponding addition unsustainable and warranting deletion. - ITAT
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