Admissibility of recorded statements and electronic evidence: CESTAT excludes non compliant statements and email printouts and sets aside revaluation ...
Corporate guarantee invocation in insolvency petition: enforceability upheld, conditional sanction letter not a novation, limitation not barred after ...
NPCI-based bank account validation for IEC applications and modifications enables real-time validation; incorrect details block submission or trigger ...
Page of 4816
Press 'Enter' after typing page number.
6441 to 6460 of 96301 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Whether cross-border receipts constitute "royalty" under Article 12 of the India-Germany DTAA: tribunal held that application of the supplier's expertise in producing data or software does not amount to imparting "information concerning industrial, commercial or scientific experience" because the customer is not enabled to independently reproduce the know-how; outcome - payments for flight data are not royalty. Software licences and restrictive contractual terms preserve supplier's title and prevent extraction of technology, so licence fees are not royalty. Ancillary training/implementation/support are incidental service payments, not transfers of know-how; sale of tangible charts remains sale of goods. Consequence - receipts are business income not taxable in India; addition deleted. - ITAT
Whether cross-border receipts constitute "royalty" under Article 12 of the India-Germany DTAA: tribunal held that application of the supplier's expertise in producing data or software does not amount to imparting "information concerning industrial, commercial or scientific experience" because the customer is not enabled to independently reproduce the know-how; outcome - payments for flight data are not royalty. Software licences and restrictive contractual terms preserve supplier's title and prevent extraction of technology, so licence fees are not royalty. Ancillary training/implementation/support are incidental service payments, not transfers of know-how; sale of tangible charts remains sale of goods. Consequence - receipts are business income not taxable in India; addition deleted. - ITAT
Note: It is a system-generated summary and is for quick reference only.