Educational approval requires mandatory State registration, but incidental surplus and trustee-owned land do not prove private benefit or profit motiv...
Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
Fraudulent import documents suspend limitation protection, while redemption of confiscated goods requires duty and interest despite bona fide purchase...
ODR arbitration participation remains mandatory after failed conciliation, while jurisdictional and maintainability objections stay available before t...
Transparency in technical bid evaluation requires disclosed standards and recorded reasons; opaque scoring invalidated tender awards and required fres...
Automated export obligation extensions remove separate regional applications after committee approval for Advance Authorisation and EPCG authorisation...
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Subscription fees received for providing online access to market research reports on the pharmaceutical sector were assessed as "royalty" deemed to accrue or arise in India under the Indo-Switzerland tax treaty. The tribunal held that the receipts were for providing information and reports without conferring any copyright or similar intellectual property right, and the customer merely obtained access to the content through an online platform; therefore, the consideration did not fall within the treaty definition of "royalty." The addition treating subscription fees as taxable royalty was deleted and the assessment order was set aside, resulting in the appeal being allowed. - ITAT
Subscription fees received for providing online access to market research reports on the pharmaceutical sector were assessed as "royalty" deemed to accrue or arise in India under the Indo-Switzerland tax treaty. The tribunal held that the receipts were for providing information and reports without conferring any copyright or similar intellectual property right, and the customer merely obtained access to the content through an online platform; therefore, the consideration did not fall within the treaty definition of "royalty." The addition treating subscription fees as taxable royalty was deleted and the assessment order was set aside, resulting in the appeal being allowed. - ITAT
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