Home Highlights June 2013 Year 2013 This

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1. Taxability of interest on income tax refund received - PE in India or not? - whether shall be taxable as business income under Article 7 of India-France DTAA as against...

2. Taxability of income in India - income from the sale of Software licenses subscription - India - Japan DTAA - CIT(A) held that the consideration received by the assessee...

3. TDS u/s 195 - Disallowance of sales commission paid to foreign agents - There is no dispute that these foreign agents do not have permanent establishment in India and...

4. Income accrued in India - Shipping income earned in India - India Singapore DTAA - income is exempt in the singapore - AO has made an attempt to deny the benefit of...

5. Compensation received on termination of network participation agreement from Citibank - Income deemed to accrue or arise in India - received does not fit into any of the...

6. Income accrues or arises in India - services to MTR foods Private Limited who is located outside India - Secondment charges paid in respect of the professional services...

7. Fees for technical services (FTS) - India France DTAA - claiming the benefit of the restricted definition under India USA DTAA - Since the assessee has been found not to...

8. Income accrued in India - Taxability of foreign income in India - Royalty receipt - Only difference is that it relates to royalty under India- Switzerland DTAA, and...

9. Income from offshore supplies - Income attribution - composite contracts - the income from offshore supplies is not liable to tax in India both u/s 44BBB as well as...

10. TDS u/s 195 - professional fees paid outside India - it cannot go to the article of ‘other income’ only because of the reason that FTS article is not there in the Double...

11. Income accrued in India - interest income and commitment fees earned by DZ Bank from its Indian clients - PE in India - Once entire interest revenues earned in India in...

12. TDS u/s 195 - on payment made to two non-residents regarding order procurement services - DTAA between India and USA/Belgium - Both the non-resident derived their income...

13. Taxability of income - Characterization of receipts - software sub-licence fee - the income in dispute, since can be classified under other Articles of the tax treaty,...

14. Income accrued or deemed to accrue in India - As the design services were inextricably connected with setting up of the plant and were rendered through this PE, the...

15. TDS u/s 195 - Scope of the term 'Interest' - Monitoring fees paid by the assssee to DEG Bank, Germany qualified as ‘interest’ both under Income-tax Act, 1961 as well as...