Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
Reassessment against a deceased assessee: procedural defect mandates fresh reassessment; nonresponsive petitioner may be treated as legal representati...
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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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