Deferred Payment of Customs Duty extended to Eligible Manufacturer Importers with electronic registration and ICEGATE authentication for conditional c...
Tariff classification determines GST schedule and rate; beverages in Schedule III attract the higher rate, tea extracts and syrups in Schedule I attra...
Fraudulent trading requires cogent evidence of intent to defraud; ordinary-course payments protected, except post-insolvency withdrawals must be resto...
Cross-charged intra-group support services under the India-UK DTAA did not meet the make available requirement for fees for technical services. The Court held that centralized support and supervision, with technical control and know-how remaining with the parent company, did not amount to transfer of technical knowledge, skill, know-how or processes to the Indian entity. Mere guidance or incidental employee skill development was insufficient because there was no material showing independent application of technical know-how by the Indian entity. The receipts were therefore not taxable as fees for technical services under Article 13, and the Revenue's appeal was dismissed.
Cross-charged intra-group support services under the India-UK DTAA did not meet the make available requirement for fees for technical services. The Court held that centralized support and supervision, with technical control and know-how remaining with the parent company, did not amount to transfer of technical knowledge, skill, know-how or processes to the Indian entity. Mere guidance or incidental employee skill development was insufficient because there was no material showing independent application of technical know-how by the Indian entity. The receipts were therefore not taxable as fees for technical services under Article 13, and the Revenue's appeal was dismissed.
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