Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Attachment of Pre Offence Mortgaged Property remains possible under PMLA; secured creditors may pursue statutory claim and seek auction with undertaki...
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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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