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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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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