Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
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Voice termination service receipts were held not to be royalty or fees for technical services under the Act or the India-USA DTAA because the payment was for a standard telecom service, with no transfer of a right in equipment, intellectual property, or any secret process. The Tribunal followed prior coordinate bench and HC rulings, and held that retrospective domestic amendments broadening "process" could not enlarge the treaty definition of royalty through Article 3(2). The receipts were therefore business profits, and in the absence of a permanent establishment in India, they were not taxable in India.
Voice termination service receipts were held not to be royalty or fees for technical services under the Act or the India-USA DTAA because the payment was for a standard telecom service, with no transfer of a right in equipment, intellectual property, or any secret process. The Tribunal followed prior coordinate bench and HC rulings, and held that retrospective domestic amendments broadening "process" could not enlarge the treaty definition of royalty through Article 3(2). The receipts were therefore business profits, and in the absence of a permanent establishment in India, they were not taxable in India.
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