Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
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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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