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1. Income deemed to accrue or arise in India - receipts of subscription fees - The ITAT had found that it did not involve the transfer of copyright or the provision of...

2. Demand - supply of technical know-how cannot be taxed under "Consulting Engineering Service" - AT

3. Payment to overseas institution as fees for awarding the degrees, supplying books and course material – There is no transfer of any technical know-how or technical...

4. Export of service or not - Since because the ultimate beneficiary is abroad, it cannot be claimed that the appellants are exporting services. Neither the place of...

5. Disallowance of royalty - capital OR revenue expenditure - The ownership/ proprietary rights in the technical know-how continue to vest in lithe censor and the assessee...

6. Classification of service - when the agreement is for transfer of exclusive/non-exclusive technical know-how the consideration received cannot be taxed under consultancy...

7. Demand of service tax - manufacture and sale of beer using the brand name and technical know-how of another person - not liable to service tax as Franchise Service or...

8. DTAA between India and Japan - Where technical services are rendered by an enterprise to another, the same falls within the ambit of the expression “technical services”...

9. Income taxable in India - Addition of receipts from Industrial Liaison program (ILP) - the Appellant is only providing administrative support to the members and not...

10. TDS u/s 195 - Scope of “make available” - The concept of make available which requires that fruits of services should remain unavailable to the service recipients in...

11. Taxability of foreign income in India - business connection’ in India or not? - subscription services - ITAT came to the factual finding that the arrangement between...

12. TDS u/s 195 - Disallowance u/s 40(a)(ia) - non-deduction of TDS on payment of management fees - It is not even the allegation of the revenue that the non-residents had...

13. Income accrued in India - fees for technical service (FTS) - Payment for certification of Diamonds - Mere rendering of services cannot be roped into FTS unless the...

14. Income deemed to accrue or arise in India - amounts received by the assessee from its Indian subsidiary towards IT and SAP charges - the services rendered under IT and...

15. Scientific and Technical Consultancy Services - Services are rendered by public funded institutions or private agencies - service rendered by the respondent in this case...