Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
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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