Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
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Consideration for project-specific designs, drawings and related deliverables was held to be an outright transfer of those documents and the associated project intellectual property, not payment for the use of, or right to use, a design. Article 12(3) of the India-UAE DTAA was interpreted as covering only use-right payments, so sale or transfer receipts fell outside royalty. Because treaty protection was claimed, the wider domestic definition of royalty could not be invoked. The receipt was therefore not taxable as royalty in India and the contrary assessment was set aside.
Consideration for project-specific designs, drawings and related deliverables was held to be an outright transfer of those documents and the associated project intellectual property, not payment for the use of, or right to use, a design. Article 12(3) of the India-UAE DTAA was interpreted as covering only use-right payments, so sale or transfer receipts fell outside royalty. Because treaty protection was claimed, the wider domestic definition of royalty could not be invoked. The receipt was therefore not taxable as royalty in India and the contrary assessment was set aside.
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