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Chambers Of Sudarshan Roy

Latest Posts by Chambers Of Sudarshan Roy

Consultancy Fees Held Not Taxable Due to Failure of “Make Available” Test

January 1, 2026 876 Views 0 comment Print

The Tribunal ruled that advisory and consultancy services could not be taxed as Fees for Included Services because no technical knowledge was transferred to clients.

Administration Fee for IMEI Allocation Not Royalty Under India–US DTAA: ITAT Delhi

November 11, 2025 435 Views 0 comment Print

ITAT Delhi condoned a delay of over 1,000 days in filing an appeal, holding that the Covid-19 period stands excluded under the Supreme Court’s suo motu extension of limitation, allowing the assessee’s appeal to proceed.

Lease income held as business profit, not royalty under India–Ireland DTAA without PE

November 9, 2025 711 Views 0 comment Print

ITAT Delhi held aircraft lease between Irish lessor and IndiGo as operating lease, not taxable in India under Article 8 of the India-Ireland DTAA.

Department to calculate 20% as per assessment order before giving effect to TDS/TCS

September 22, 2023 4830 Views 0 comment Print

Orion Security Solutions P. Ltd. Vs DCIT (Delhi High Court) Headnote: TDS and TCS have to be adjusted against the amount arrived at by applying the rate of 20% against the tax crystalized as per the assessment order. Facts in brief: 1. The Assessee had filed its return of income for the assessment year 2021-22 declaring […]

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