Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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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