Home Highlights January 2012 Year 2012 This

You may also like:

1. Tax payable u/s 115-O - dividend distribution tax rate being restricted by the treaty provision dealing with taxation of dividends in the hands of the shareholders (i.e....

2. TDS u/s 195 - Since Section 40(a)(i) as it stood in AY 2006-07 continued to discriminate in the above manner and was inconsistent with Article 24(3) of the Indo Japan...

3. Indo-French DTAA – Article 5 of India France DTAA states that even existence of a computer server amounts to existence of a PE within a jurisdiction...... - AAR

4. 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...

5. Rental income or otherwise - mesne profit - TAT was right in holding that mesne profits and interest on mesne profits received under the direction of the Civil Court for...

6. Taxability of Bogus purchase - Estimation of profit - in cases where purchases are not proved with necessary evidences, only profit element embedded on those purchases...

7. Taxability of income in India - Interest income on income tax refund - As referring to relevant Article 11 of Indo-US DTAA with regard to interest it can be concluded...

8. Income accrued in India - tratement of Income from cloud hosting services as royalty - income from cloud hosting services has erroneously held as royalty within the...

9. Addition u/s. 40(a)(ia) r.w. 195 - The rendition of services for earning commission cannot be of such a nature that there is a transfer of technology, in the sense it is...

10. 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’...

11. Estimation of income - AO has made 100% addition, whereas the CIT(A) has scaled down addition to 12.50% profit on alleged bogus purchases. - Although, both authorities...

12. Benefit of DTAA against Dividend Distribution Tax (DDT) - whether the benefit of DTAA can be extended to domestic company? - The Protocol with reference to Article 10 as...

13. Royalty u/s 9(1)(iv) – Article 13 of Indo-French DTAA – Consideration received from distribution agreement - Whether news reports and photographs could be subject matter...

14. Indo French DTAA - PE - Since there are no findings by the A.O., or the DRP, to the effect that the transactions between the agent and the assessee are not at an arm's...

15. Initiation of CIRP - Pre-Existing Disputes - This Tribunal is of the considered view that there is a Pre-Existing Dispute and the aforenoted correspondence establishes...