Unlawful outward remittances via Hawala using proforma invoices and electronic records proved; documents admitted, directors penalised, penalties redu...
Attachment of equivalent-value properties as proceeds of crime upheld; preventive attachment order and confirmation sustained; no independent ED reinv...
Broker trading-system "technical glitch" redefinition and narrowed incident-reporting regime for large IBT/STWT brokers requiring 2-hr notice and 14-w...
Taxability of transponder service fees was addressed as whether such payments constitute royalty under the India-UK tax treaty, with the tribunal applying the principle that unilateral domestic amendments do not alter treaty definitions; accordingly the amended domestic definition of process/royalty was not imported into the treaty, and payments for transponder services were held not to fall within the treaty definition of royalty, disposing of the withholding obligation under the treaty analysis. The tribunal upheld the appellate authoritys rejection of revenues contention and did not adjudicate separate issues on fees for technical services or business profits due to absence of contested grounds.
Taxability of transponder service fees was addressed as whether such payments constitute royalty under the India-UK tax treaty, with the tribunal applying the principle that unilateral domestic amendments do not alter treaty definitions; accordingly the amended domestic definition of process/royalty was not imported into the treaty, and payments for transponder services were held not to fall within the treaty definition of royalty, disposing of the withholding obligation under the treaty analysis. The tribunal upheld the appellate authoritys rejection of revenues contention and did not adjudicate separate issues on fees for technical services or business profits due to absence of contested grounds.
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