Co-operative credit society deduction on bank deposit interest upheld where funds were business funds and income remained attributable to member credi...
Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
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The limitation and reopening challenge to the reassessment became infructuous after the Finance Act 2026 amended section 153B, so no merit survived in that ground. On the substantive taxability issue, receipts from voice termination, bandwidth, and annual operation and maintenance services were held not taxable in the manner adopted by the assessment order because the facts were identical to the assessee's earlier year, and Article 12 of the India-Singapore and India-USA DTAAs were treated as pari materia on royalties, fees for technical services, and the make available requirement. The Tribunal followed the earlier decisions and allowed the assessee's claim.
The limitation and reopening challenge to the reassessment became infructuous after the Finance Act 2026 amended section 153B, so no merit survived in that ground. On the substantive taxability issue, receipts from voice termination, bandwidth, and annual operation and maintenance services were held not taxable in the manner adopted by the assessment order because the facts were identical to the assessee's earlier year, and Article 12 of the India-Singapore and India-USA DTAAs were treated as pari materia on royalties, fees for technical services, and the make available requirement. The Tribunal followed the earlier decisions and allowed the assessee's claim.
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