Imported analyser diagnostic cartridges treated as accessories with analyser system, not standalone diagnostic reagents; extended limitation and penal...
Steel-timber construction shuttering/formwork tariff classification dispute: essential character held steel, classified as shuttering under Heading 73...
Family-linked property purchases using fabricated loan agreements and benami-style arrangements held to be crime proceeds; attachment upheld, appeal d...
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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