Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
Appointment of Registrars as adjudicating officers under Companies Act reallocates territorial jurisdiction and sets appeal route to Regional Director...
Composite supply of drilling services and site specific chemicals characterised as composite supply; prior advance rulings set aside, tax rate left op...
Cross country pipeline classification and ITC entitlement: pipelines outside factory treated as immovable, ITC disallowed under Section 17 restriction...
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Taxation of fees for technical services under Article 12 of the India-Singapore DTAA was addressed: the Tribunal applied the limited scope of Article 9 as a neutralisation rule for intra-group profit adjustments and rejected recharacterisation of the transaction. The assessee, a Singapore entity, was treated as a distinct legal person and its refurbishing services were held not taxable in India because Article 12(3) did not apply and Article 12(4)(a) was inapplicable since the services were not rendered in connection with payments described in paragraph 3. The Tribunal followed coordinate-bench precedent and deleted the addition for fabrication charges; appeal allowed.
Taxation of fees for technical services under Article 12 of the India-Singapore DTAA was addressed: the Tribunal applied the limited scope of Article 9 as a neutralisation rule for intra-group profit adjustments and rejected recharacterisation of the transaction. The assessee, a Singapore entity, was treated as a distinct legal person and its refurbishing services were held not taxable in India because Article 12(3) did not apply and Article 12(4)(a) was inapplicable since the services were not rendered in connection with payments described in paragraph 3. The Tribunal followed coordinate-bench precedent and deleted the addition for fabrication charges; appeal allowed.
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