Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
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...
Fiscal transparency of a UK partnership requires Indian-source income to be tested partner by partner for treaty entitlement. Article 4(1)(b) of the India-UK DTAA limits protection to the share taxed as income of a UK resident, whether in the partnership's or partners' hands; it does not bar non-UK resident partners from invoking India's treaty with their own residence State. Domestic recognition of the partnership does not establish a single treaty residence. Treaty claims require residence certificates and prescribed information. Legal-professional services are not automatically fees for technical services merely because India-UK treaty relief is unavailable; their characterisation must satisfy domestic law and the applicable treaty's income article, including relevant fixed-base, permanent-establishment, or presence conditions.
Fiscal transparency of a UK partnership requires Indian-source income to be tested partner by partner for treaty entitlement. Article 4(1)(b) of the India-UK DTAA limits protection to the share taxed as income of a UK resident, whether in the partnership's or partners' hands; it does not bar non-UK resident partners from invoking India's treaty with their own residence State. Domestic recognition of the partnership does not establish a single treaty residence. Treaty claims require residence certificates and prescribed information. Legal-professional services are not automatically fees for technical services merely because India-UK treaty relief is unavailable; their characterisation must satisfy domestic law and the applicable treaty's income article, including relevant fixed-base, permanent-establishment, or presence conditions.
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TaxTMI 
TaxTMI 
of 4912 
