Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Whether consideration for ancillary support services connected to software license distribution constitutes Fee for Technical Services under the IndiaSingapore DTAA. The tribunal found the services were ancillary and subsidiary to software sales, including maintenance and technical support obligations under the parties' licence and partner agreements, and thus not characterisable as FTS or as "make available" independent services; consequence: the assessing officer/TPA/DRP findings treating the receipts as FTS were not justified and were disallowed to that extent.
Whether consideration for ancillary support services connected to software license distribution constitutes Fee for Technical Services under the IndiaSingapore DTAA. The tribunal found the services were ancillary and subsidiary to software sales, including maintenance and technical support obligations under the parties' licence and partner agreements, and thus not characterisable as FTS or as "make available" independent services; consequence: the assessing officer/TPA/DRP findings treating the receipts as FTS were not justified and were disallowed to that extent.
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