Cash routed to non-existent firm deemed proceeds of crime; laundered funds and properties attachable, provisional attachments confirmed; two accounts ...
Continuation of Section 73 service-tax proceedings after provider's death (construing s.65(7)) - held to abate; posthumous OIO and recoveries invalida...
Change of corporate management after approved resolution plan - writ maintainable; property attachment not 'transfer' under PBPT; Section 32A protecti...
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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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