Appellate jurisdiction over baggage imports is excluded, requiring confiscation challenges involving passenger-carried gold to proceed by statutory re...
Article 227 review permits intervention in arbitration only for manifest, patent inherent jurisdictional defects, not representational authority dispu...
Customer-referral commission, calculated as a fixed percentage of sales to referred customers, does not constitute fees for technical services under the India-Netherlands tax treaty or the Act where no technical or consultancy service, design, technology, or know-how is provided or made available for independent future use. Such commission is business income and is not taxable in India under the treaty in the absence of a permanent establishment. Beneficial treaty treatment must be given effect, and withholding-tax credit relating to interest on income-tax refunds must be granted in accordance with law.
Customer-referral commission, calculated as a fixed percentage of sales to referred customers, does not constitute fees for technical services under the India-Netherlands tax treaty or the Act where no technical or consultancy service, design, technology, or know-how is provided or made available for independent future use. Such commission is business income and is not taxable in India under the treaty in the absence of a permanent establishment. Beneficial treaty treatment must be given effect, and withholding-tax credit relating to interest on income-tax refunds must be granted in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4905 
