Classification of imported salvaged shaft pieces as ship parts confirmed, reassessment time-barred and appeal allowed restoring original classificatio...
Scope of intermediary status for data hosting services: tribunal finds provider not intermediary, services exported and not taxable, limited remand on...
CENVAT credit availability after omission of Rule 12B in textiles confirmed; late addendum to SCN introducing new grounds held time-barred and invalid...
Export of Wheat Flour and related products subject to online allocation, eligibility criteria, non-transferable six-month authorisations and reporting...
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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