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Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
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Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Cross-segment derivatives manipulation: integrated order patterns can support interim restraints, while director liability requires responsibility, co...
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 4907 
