Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Cloud-based communication platform subscription fees are not royalty where subscribers receive only limited, non-exclusive access and no copyright, source code, intellectual property, or embedded process is transferred. The provider's use of technology and processes to deliver the service does not give subscribers a right to use those processes. Such receipts constitute business income and are not taxable in India absent a permanent establishment. Tax deducted at source credit requires factual verification before it may be allowed in accordance with law.
Cloud-based communication platform subscription fees are not royalty where subscribers receive only limited, non-exclusive access and no copyright, source code, intellectual property, or embedded process is transferred. The provider's use of technology and processes to deliver the service does not give subscribers a right to use those processes. Such receipts constitute business income and are not taxable in India absent a permanent establishment. Tax deducted at source credit requires factual verification before it may be allowed in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
