Proportionate interest, unexplained credits and partner remuneration disputed; proofs of fund nexus and lender identity were decisive and disallowance...
Capital gains valuation from stamp assessment versus net consideration for residential reinvestment: deemed stamp value replaced for gains but not for...
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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