Service of notice and contractual debt acknowledgment preserved insolvency admission against a corporate guarantor despite limitation and natural just...
Original works exemption excludes standalone boulder transportation, leaving subcontracted railway-project transport services subject to service tax l...
Annual production capacity determinations excluding stenter galleries support refunds for unconstitutional excise levies without an unjust-enrichment ...
Vicarious liability for cheque dishonour requires specific allegations of responsibility and cheque signatory; generic director allegations cannot sus...
IT Resilience Index requires market infrastructure institutions to automate resilience scoring, early warnings, and continuous service-delivery monito...
Under the India-Singapore DTAA, receipts from maintenance support and other services, and education and training services were examined for characterization as fees for technical services, including whether the "make available" requirement in Article 12(4)(b) was satisfied. Applying coordinate bench precedents, it was held that these services did not "make available" technical knowledge, experience, skill, know-how, or processes to enable the payer to apply them independently. Since the burden lay on the Revenue to establish satisfaction of the "make available" condition and no supporting evidence was produced by the tax authorities, the addition was directed to be deleted and the taxpayer's ground was allowed. - ITAT
Under the India-Singapore DTAA, receipts from maintenance support and other services, and education and training services were examined for characterization as fees for technical services, including whether the "make available" requirement in Article 12(4)(b) was satisfied. Applying coordinate bench precedents, it was held that these services did not "make available" technical knowledge, experience, skill, know-how, or processes to enable the payer to apply them independently. Since the burden lay on the Revenue to establish satisfaction of the "make available" condition and no supporting evidence was produced by the tax authorities, the addition was directed to be deleted and the taxpayer's ground was allowed. - ITAT
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