Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
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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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