Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
