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...
Whether transponder service fees constitute 'royalty' under Article 13 of the India-UK DTAA and attract withholding under domestic TDS law. Relying on binding High Court precedents, the treaty term 'process' must be read as 'secret process' and unilateral domestic statutory amendments cannot be imported into the DTAA; therefore payments for satellite transponder services are characterisable as consideration for services, not royalty. Consequence: no withholding obligation arose on the payer under the domestic TDS regime in respect of those transponder service fees.
Whether transponder service fees constitute 'royalty' under Article 13 of the India-UK DTAA and attract withholding under domestic TDS law. Relying on binding High Court precedents, the treaty term 'process' must be read as 'secret process' and unilateral domestic statutory amendments cannot be imported into the DTAA; therefore payments for satellite transponder services are characterisable as consideration for services, not royalty. Consequence: no withholding obligation arose on the payer under the domestic TDS regime in respect of those transponder service fees.
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