Arbitration of SEZ sub-lease monetary claims preserves rent, maintenance, termination, improvements and damages disputes while unused premises are vac...
Scientific research approval grants a research association tax recognition, subject to annual donor reporting, certification, and regulatory complianc...
Judicial discipline requires consistent reassessment treatment where identical facts were decided for the same taxpayer in the preceding assessment ye...
Royalty and fees for technical services under the India-Germany DTAA are taxable on receipt rather than accrual basis. Consideration for restricted, non-exclusive standard software licences that do not transfer copyright rights is not royalty under the Act or treaty. Separate scopes of work, invoicing, consideration and no profit-and-loss sharing prevent consortium members from constituting an association of persons; joint and several liability and indemnities alone are insufficient. Offshore equipment-supply income is not taxable in India merely because it forms part of a composite project. Transfer-pricing adjustments require a prescribed method and cannot rest on an ad hoc mark-up where transaction differences are reconciled and benchmarking is undisputed.
Royalty and fees for technical services under the India-Germany DTAA are taxable on receipt rather than accrual basis. Consideration for restricted, non-exclusive standard software licences that do not transfer copyright rights is not royalty under the Act or treaty. Separate scopes of work, invoicing, consideration and no profit-and-loss sharing prevent consortium members from constituting an association of persons; joint and several liability and indemnities alone are insufficient. Offshore equipment-supply income is not taxable in India merely because it forms part of a composite project. Transfer-pricing adjustments require a prescribed method and cannot rest on an ad hoc mark-up where transaction differences are reconciled and benchmarking is undisputed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4905 
