RPA (Remote Pilot Aircraft) for military use defined to include drones/UAV/UAS; exemptions limited to specified defence imports with Joint Secretary c...
Transfer of going concern and transfer of input tax credit under GST allowed; exemption applies though interstate ledger transfers left to authorities...
Reimbursements received from Indian group entities for actual salary costs of seconded employees could not be taxed as fees for technical services under section 9(1)(vii) and Article 12(4) of the India-Japan DTAA because the contracts and appointment letters established an employer-employee relationship between the secondees and the Indian entities, making the payments in substance salary and not consideration for rendering technical services; accordingly, the reimbursements were not recharacterizable as FTS and the addition was deleted, allowing the appeal. - ITAT
Reimbursements received from Indian group entities for actual salary costs of seconded employees could not be taxed as fees for technical services under section 9(1)(vii) and Article 12(4) of the India-Japan DTAA because the contracts and appointment letters established an employer-employee relationship between the secondees and the Indian entities, making the payments in substance salary and not consideration for rendering technical services; accordingly, the reimbursements were not recharacterizable as FTS and the addition was deleted, allowing the appeal. - ITAT
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