Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
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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