Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
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Payments for project-specific architectural and structural design services to Singapore entities were not fees for technical services because the India-Singapore DTAA "make available" test was not satisfied: the services did not transfer technical knowledge, skill, know-how or processes for independent use by the assessee. As the treaty condition failed, tax was not required to be deducted under section 195, and the disallowance under section 40(a)(i) was correctly deleted. The Tribunal also followed its earlier order in the assessee's own case for the immediately preceding year, finding no distinguishing facts.
Payments for project-specific architectural and structural design services to Singapore entities were not fees for technical services because the India-Singapore DTAA "make available" test was not satisfied: the services did not transfer technical knowledge, skill, know-how or processes for independent use by the assessee. As the treaty condition failed, tax was not required to be deducted under section 195, and the disallowance under section 40(a)(i) was correctly deleted. The Tribunal also followed its earlier order in the assessee's own case for the immediately preceding year, finding no distinguishing facts.
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