International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
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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