Maintainability of a Section 7 insolvency petition against a financial service provider denied; appeal dismissed for non maintainability and complex d...
Provisional attachment under Prevention of Money Laundering Act requires exhaustion of statutory remedies; impugned order set aside, appeal to tribuna...
Restoration of property under Prevention of Money Laundering Act after attachment dispute rendered academic; possession directed to successful resolut...
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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