Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
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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