https://www.taxtmi.com/caselaws?id=400660 Time charter receipts for a vessel with crew were treated as consideration for services, not royalty, because the owner retained exclusive control and the charterer obtained no independent possession or right to use the equipment. On that basis, mobilisation fees linked to the same charter arrangement were also held outside royalty. Reimbursement receipts could not be conclusively classified on the existing record and were remitted for factual verification. TDS credit was also restored for examination, with interest to be recomputed consequentially. The challenge to initiation of penalty proceedings was rejected as premature. en-us Mon, 09 Nov 2020 00:00:00 +0530 Thu, 12 Nov 2020 12:50:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=400660 Time charter receipts for a vessel with crew were treated as consideration for services, not royalty, because the owner retained exclusive control and the charterer obtained no independent possession or right to use the equipment. On that basis, mobilisation fees linked to the same charter arrangement were also held outside royalty. Reimbursement receipts could not be conclusively classified on the existing record and were remitted for factual verification. TDS credit was also restored for examination, with interest to be recomputed consequentially. The challenge to initiation of penalty proceedings was rejected as premature. Case-Laws Income Tax Mon, 09 Nov 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=400660