PMLA anticipatory bail requires satisfaction of twin conditions, while predicate-offence protection does not extend to independent money-laundering pr...
School-affiliation charges remain taxable where not directly connected with examinations, while extended limitation requires proof of deliberate tax e...
Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
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Underwriting commission paid to a non-resident for assuring subscription of an issue was held not to be fees for technical services under the India-UK DTAA or section 9(1)(vii). The Tribunal applied the treaty's make available requirement and found that no technical knowledge, experience or skill was passed on to the Indian clients. It further held that underwriting is only an undertaking to take up any unsubscribed portion of the shares, which does not amount to rendering technical or consultancy services. The commission was therefore not taxable in India, and the Revenue's appeal was dismissed.
Underwriting commission paid to a non-resident for assuring subscription of an issue was held not to be fees for technical services under the India-UK DTAA or section 9(1)(vii). The Tribunal applied the treaty's make available requirement and found that no technical knowledge, experience or skill was passed on to the Indian clients. It further held that underwriting is only an undertaking to take up any unsubscribed portion of the shares, which does not amount to rendering technical or consultancy services. The commission was therefore not taxable in India, and the Revenue's appeal was dismissed.
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