Religious purpose exclusion versus charitable purpose: non overriding religious objects do not attract Explanation 3, registration directed under sect...
Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
Proceeds of crime: provisional attachment confirmed; equivalent value attachment and acquisition date fair market value upheld, Covid exclusion preser...
Receipts from title search services were held not to be royalty under Article 12(3) of the India-US DTAA because the provider only supplied extracts of public-domain information and did not transfer specialised know-how, methodology, or any right to use a process. Receipts from marketing support services were also held not to be fees for included services, as the advice and assistance provided did not satisfy the make available test under Article 12(4)(b) read with the Protocol. The corresponding additions were deleted; grounds relating to interest and penalty initiation were dismissed.
Receipts from title search services were held not to be royalty under Article 12(3) of the India-US DTAA because the provider only supplied extracts of public-domain information and did not transfer specialised know-how, methodology, or any right to use a process. Receipts from marketing support services were also held not to be fees for included services, as the advice and assistance provided did not satisfy the make available test under Article 12(4)(b) read with the Protocol. The corresponding additions were deleted; grounds relating to interest and penalty initiation were dismissed.
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