Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Development rights transfers treated as immovable property, while construction abatement applies and repeated non-payment permits extended service-tax...
Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
Whether milestone payments constituted "fees for technical services" under Article 12(4) of the India-Germany DTAA: Tribunal found that milestone deliverables (organizational diagrams, work programmes, quality assurance plans, preliminary system design) were preparatory, non-independent steps integral to supply, installation and maintenance of rolling stock and did not amount to managerial, technical or consultancy services within Article 12(4); accordingly payments for Milestones A1, A3, A5 and A10 are not taxable as FTS. Charging of interest under section 234B: applying the Supreme Court's ruling on the prospective operation of the proviso to section 209(1), no interest under section 234B was chargeable for AY 2008-09. - ITAT
Whether milestone payments constituted "fees for technical services" under Article 12(4) of the India-Germany DTAA: Tribunal found that milestone deliverables (organizational diagrams, work programmes, quality assurance plans, preliminary system design) were preparatory, non-independent steps integral to supply, installation and maintenance of rolling stock and did not amount to managerial, technical or consultancy services within Article 12(4); accordingly payments for Milestones A1, A3, A5 and A10 are not taxable as FTS. Charging of interest under section 234B: applying the Supreme Court's ruling on the prospective operation of the proviso to section 209(1), no interest under section 234B was chargeable for AY 2008-09. - ITAT
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