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1. TDS u/s 195 - Disallowance u/s 40(a)(i) - the said income in the hands of non-resident has to be considered in the light of the provisions of DTAA between India and the...

2. Clubbing of income of Non-resident and Permanent Establishment (PE) - Levy of surcharge at 5% as against assessee’s claim of 2% - The royalty and Fee for Technical...

3. Income accrued in India - interest income on loans in the form of suppliers credit given to Indian parties - As alleged that the Indian parties from whom the assessee...

4. Income accrued in India - taxation of interest income - assessee is a company incorporated and fiscally domiciled in the Republic of Japan - For interplay of Article...

5. Income accrued in India - Taxability as Royalty income - the income earned by the assessee from sale of software, either directly to the customers in India or through...

6. Taxability of income in India - Income attributable to India - income of advertisement and subscription revenue - Permanent Establishment (PE) - business connection -...

7. Income taxable in India or not - Taxation of Technical Collaboration Fees @ 10% u/s. 9(1)(vii) r.w.s 115A(1)(b) - The Appellate Tribunal considered the arguments...

8. Payment received from resellers in India for acquisition of computer software - Assessee who is a non resident does not have a permanent establishment and therefore...

9. Income accrued in India - Permanent Establishment (PE) - the distribution income earned by the assessee cannot be taxed in India because Taj India does not constitute an...

10. Income accrued in India - Centralized services fee received - royalty or fee for technical services The payments received were rightly held by the Tribunal, to be in the...

11. 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...

12. Income accrued in India - Article for taxability of FTS under the India Thailand Treaty - Existence of PE in India - The assessee company has no Permanent Establishment...

13. Income accrued in India - permanent establishment (PE) - Withholding of tax in India - vessel engaged in seismic survey at high sea - The sum paid by the applicant to...

14. Nature of unaccounted surrendered income emanating from the seized document - business income OR deemed income u/s 69 - The income is business income relatable to...

15. Characterization of receipts - Treatment of interest income from staff loans and advances, interest income from other loans and advances and miscellaneous income -...