Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
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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