The
present ruling reiterates the principle that transfer of technology is a
condition precedent to satisfy the ‘make available’ criteria. The phase ‘make
available’ has been the subject matter of many rulings in India, wherein it has
been held that the recipient should be in a position to derive an enduring
benefit and is in a position to utilize the knowledge or know-how in future on
its own. The ruling indicates that transfer of blueprints, i.e., technical
plans, designs etc. which enables the payer to use the same without recourse to
the provider of services, for executing projects in the future, satisfies the
test of ‘make available’ and, accordingly, is taxable as FIS
Sunday, 28 July 2013
Mumbai ITAT rules that blueprints, to be used in future, satisfy the test of ‘make available
Subscribe to:
Post Comments (Atom)
Interest on Foreign Currency Loan & Corresponding Forex Loss for Strategic Share Acquisition Held Deductible as Revenue Expenditure
The tax treatment of interest on funds borrowed to acquire shares hinges on a single, crucial distinction: the purpose behind the acqu...
-
A new website launched for TDS related matters www.tdscpc.gov.in TRACES – T DS R econciliation A nalysis and C orrection E nabling S yste...
-
Section 68 -Cash credits Section 69 -Unexplained investments Section 69A - Unexplained money, etc Section 69B -Amount of investme...
-
The overall effective tax rate of a U.S. multinational corporation may have significant impact on the value of its stock. Therefore, it ...
-
An eminent concern within the GST framework pertains to the entitlement of Input Tax Credit (ITC) concerning expenditures associated with In...
-
There are certain changes in India's tax rules for TDS on payments made to non-residents. The Income Tax Act, 2025 ('ITA 2025'...
-
Recent judicial pronouncements across different forums have clarified several important aspects of Indian income tax law, particularly relat...
-
Ahmedabad Tribunal Special Bench has ruled that corpus distributed on dissolution of an offshore discretionary trust to resident Indian be...
-
The posting had been move to another website. Please click the link below to get the access of the same. https://taxofindia.wordpress....
-
Did you come across many errors and mistakes while checking your CIBIL report status? Are you wondering how to clear yourself out of CIBIL ...
-
The Income Tax department has been modified the Form No. 15G & 15G as per amended notification No. 11/2013 [F.NO.142/31/2012-SO(TPL)]/...
No comments:
Post a Comment