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...
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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