Request-driven road restoration attracts reverse-charge GST, not governmental-function treatment or compensatory-damages status for business recipient...
Road restoration charges for commercial pipeline works are taxable Government services, with reverse charge liability and no public-function exemption...
Model-wise import cap monitoring cannot justify withholding used multifunction machines where all-India tracking is absent and full security is furnis...
Article 5(2)(l) of the India-USA DTAA requires cumulative satisfaction of services being furnished or performed in India through employees or other personnel for the prescribed period before a service permanent establishment arises. Cost-to-cost reimbursements of expenditure initially incurred and later cross-charged without mark-up do not establish such a presence where the activity is performed remotely and the non-resident's employees or personnel have no physical presence in India. In those circumstances, no service permanent establishment or taxable income in India arises from the reimbursements.
Article 5(2)(l) of the India-USA DTAA requires cumulative satisfaction of services being furnished or performed in India through employees or other personnel for the prescribed period before a service permanent establishment arises. Cost-to-cost reimbursements of expenditure initially incurred and later cross-charged without mark-up do not establish such a presence where the activity is performed remotely and the non-resident's employees or personnel have no physical presence in India. In those circumstances, no service permanent establishment or taxable income in India arises from the reimbursements.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
