Genuineness of investment evidence determines LTCG entitlement; non specific regulatory reports cannot displace transaction specific documentary proof...
Import entitlement for repairs and after sales service extends to authorised service agents; provisional release allowed subject to bond and quantitat...
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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