Charity-run tree plantation and maintenance for environmental preservation qualifies as "charitable activity", making supplies GST-exempt under Notifi...
Drawings/designs supply and erection supervision fees from German contractor: designs non-taxable; supervision taxed as FTS/PE depending on six-month ...
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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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