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1. Income taxable in India - cellular roaming charges - India-UK DTAA under Article 13(3) - Royalty - VIL already possessed the process used for providing roaming services...

2. Addition on account of services rendered by the assessee to its AE in India - whether FTS under the provisions of Article 13(4)(c) of the India-UK DTAA? - the...

3. Disallowance u/s 40(a)(ia) - failure to deduct TDS u/s 195 - in view of Protocol between India and Spain, the restrictive meaning of ‘Fee for Technical Services’...

4. Fees for Technical Services (FTS) - The AO himself has stated that some of the services are of the nature of FTS. Thus, AO clearly admits that all the services rendered...

5. 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...

6. Insurance Auxiliary Services - brokerage received from overseas reinsurance - Export of service or not - Non receipt of consideration in foreign exchange - the basis of...

7. Establishment of PE in India – service PE - Article 5 of Indo-UK DTAA – It is thus rightly held that the service PE of the assessee is established in India - AT

8. Income accrued in India - Royalty u/s.9(1)(vi) - intra-group services fees - Coming to the Indo-Spain DTAA, it is axiomatic that the domestic law has not been linked...

9. Foreign tax credit claimed under Article 24 of India- UK DTAA read with Section 90 - assessee who is a resident of India and has derived from salary which has suffered...

10. FTS in the given case would be taxed at the beneficial rate of 15% on gross receipts as provided in Article 13(2) of the India-UK DTAA. - the tax liability borne by GRSE...

11. 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...

12. Business Auxiliary Services - intermediary services - Sub-section(2) of Section 13 specifically provides that the place of supply of services except the services...

13. Corporate guarantee - fee for technical services (FTS) under article 13 of the India France DTAA and section 9(1)(vii) - services of corporate guarantee by the assessee...

14. DTAA with New Zealand - Exchange of information - Article 26 as amended.

15. DTAA with Slovenia - Exchange of information - Article 26 as amended w.e.f. 1.3.2017