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“Section 2(31)(vii)”
Section References (mined)Section 2Section 2(31)(vii)1 judgments
The decision most relied on for Section 2(31)(vii) is Para 3.1, 5.2, 12.1, 13 8. DCIT v. Boston Consulting Group Pte. Ltd. (94 ITD 31), cited in 40 judgments on BharatTax.
Leading authorities on Section 2(31)(vii)
Para 3.1, 5.2, 12.1, 13 8. DCIT v. Boston Consulting Group Pte. Ltd.
94 ITD 31 · 2005 · ITAT
40
citing judgments
The Delhi Tribunal, in citing Boston Consulting Group, examines the taxability of fees for services, particularly concerning whether such fees constitute 'fees for technical services' under Indian domestic law or are covered by a tax treaty. The decision likely clarifies the application of treaty provisions over domestic law for certain service fees when determining the taxability of a foreign enterprise in India.
Linde AG, Linde Engg. Division v. Dy. DIT
44 Taxmann.com 244 · 2014 · High Court
24
citing judgments
A consortium formed for bidding on an infrastructure contract is not an 'association of persons' for tax purposes if it acts as a pass-through entity.