Straight-line lease rental accounting change results in penalty quashed where disclosed accounts and bona fide arguable accounting interpretation exis...
Allocation of enhanced FSI/TDR proceeds between cooperative society and individual flat-owners; tribunal deletes society LTCG addition, remits 80P ver...
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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