Road restoration charges constitute taxable services when requested for commercial pipeline activity, requiring reverse-charge GST from the business r...
Interest on delayed release of requisitioned cash includes statutory pre-assessment interest and restitutionary compensation for unlawful post-assessm...
Incomplete inventory records justify rejecting accounts, while profit estimation requires relevant comparable material and interest falls under other ...
Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Income characterization and treaty limits govern taxability: payments characterized as "royalty" under domestic law may attract tax at treaty rates under the Indo Swiss DTAA and be subject to levy under section 115A, but additional surcharge and cess over the treaty rate are not permissible following recent tribunal precedent. Separately, amounts paid by resident end users or distributors to non resident software suppliers under licenses or EULAs have been held not to constitute royalty for use of copyright and therefore do not give rise to Indian tax withholding obligations on that basis.
Income characterization and treaty limits govern taxability: payments characterized as "royalty" under domestic law may attract tax at treaty rates under the Indo Swiss DTAA and be subject to levy under section 115A, but additional surcharge and cess over the treaty rate are not permissible following recent tribunal precedent. Separately, amounts paid by resident end users or distributors to non resident software suppliers under licenses or EULAs have been held not to constitute royalty for use of copyright and therefore do not give rise to Indian tax withholding obligations on that basis.
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