Minimum Public Offer Requirements set tiered issuer-based allotment minima with mandatory staged public shareholding increases and exchange enforcemen...
Disallowance under tax law for investment expenses cannot be applied mechanically; authority must record clear reasons before increasing assessee's su...
Fees for Included Services under Article 12(4)(a)/(b) of the India-USA DTAA were examined: consultancy and support services receipts were held not to constitute FIS where the foreign supplier did not make available technical expertise or skills but transferred commercial information or provided non-manufacturing support; accordingly additions were deleted. Subscription fees were held not to be 'royalty' as they provide use of a copyrighted article rather than a right to exploit copyright. TDS credit is allowable to the taxpayer provided the corresponding income is offered to tax and the AO considers available TDS proof when determining liability.
Fees for Included Services under Article 12(4)(a)/(b) of the India-USA DTAA were examined: consultancy and support services receipts were held not to constitute FIS where the foreign supplier did not make available technical expertise or skills but transferred commercial information or provided non-manufacturing support; accordingly additions were deleted. Subscription fees were held not to be 'royalty' as they provide use of a copyrighted article rather than a right to exploit copyright. TDS credit is allowable to the taxpayer provided the corresponding income is offered to tax and the AO considers available TDS proof when determining liability.
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