Form 26AS evidence requires successor-entity accounting verification after business transfer, while invoice-supported related-party advertising expend...
Money-laundering judgment timing requires awaiting the scheduled-offence decision despite continuation of the underlying trial where outcomes directly...
Accredited investor eligibility expands through securities-market exposure, while alternative investment fund disputes require prescribed resolution a...
Whether a portion of consideration paid under a global partnership agreement for on-ground advertising and the right to use event-related marks constituted "royalty" under s.195 read with the Indo-Singapore DTAA was determined by construing the agreement as creating a substantive licence to use the relevant trademark worldwide across "advertising material" in any medium. The payer's own admissions and contemporaneous correspondence showed trademark use could not be treated as merely incidental to advertising. Since the apportionment of the composite consideration into advertising (2/3) and trademark licence (1/3) was not substantially disputed, treating 1/3 as royalty and requiring withholding tax at 15% on that portion was upheld. - HC
Whether a portion of consideration paid under a global partnership agreement for on-ground advertising and the right to use event-related marks constituted "royalty" under s.195 read with the Indo-Singapore DTAA was determined by construing the agreement as creating a substantive licence to use the relevant trademark worldwide across "advertising material" in any medium. The payer's own admissions and contemporaneous correspondence showed trademark use could not be treated as merely incidental to advertising. Since the apportionment of the composite consideration into advertising (2/3) and trademark licence (1/3) was not substantially disputed, treating 1/3 as royalty and requiring withholding tax at 15% on that portion was upheld. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
