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As per Income tax Act, by Explanation 6 to section 9(1)(vi), it is clarified that process includes transmission by satellite (including uplinking, amplification, conversion for down linking of any signal), cable, optic fibre or by any other technology, whether or not such process is secret).
A question would arise whether as per the proposal, tax authorities could resort to meaning of process under the Act to interpret the scope of royalty as per DTAA.
In line with the recommendation of Income tax Simplification Committee in its final report, it has now been proposed to insert Explanation 4 to section 90 and section 90A to provide that where any term used in agreement entered into under section 90(1)/90A(1) of the Act is defined under the said agreement, the said term shall be assigned the meaning as provided in the said agreement and where the term is not defined in the agreement, but is defined in the Act, it shall be assigned meaning as defined in the Act and any explanation issued by the Central government.
As per Memorandum to Finance Bill, 2017, as part of rationalization measures, the proposed amendment has been inserted with a view to bring in more clarity in the Act in respect of interpretation of 'terms' used in DTAA for the purpose of its application in order to reduce the avoidable litigation related to taxation of non-residents.
The casein proteins aggregate into so called “casein micelles” of spherical shape and ca. Bovine milk is white because of the 1015 casein micelles (nano ping pong balls) dispersed in every m L of milk.
In general, morals correspond to what actually is done in a society. This confusion between descriptive and prescriptive ethics occurs quite often by persons untrained in philosophical analysis.
Historically, but less so today, private persons or partnerships could carry on the business of a bank; mostly receiving monies on deposit, paying interest on those deposits, and extending loans of those monies to third-paryies at a higher rate of interest.