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1. The benefit of Article 8 of the India–Germany DTAA would also be available to the assessee in respect of the revenue earned by it from the feeder vessels obtained on...

2. 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...

3. Applicability of Article 8 vis-a-vis Article 24 of DTAA - DTAA between India and Singapore - shipping income - Article 24 only envisages territorial and jurisdictional...

4. 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...

5. DTAA - once it is held that chartering includes slot charter, space charter and it falls within the ambit of “operation of ships”, then the benefit of Article 8 cannot...

6. PE in India - India-Spain DTAA - business profit carried out through PE - Services rendered from outside India - there is no Permanent Establishments during the relevant...

7. Permanent Establishment under Article 5 of the DTAA between India and U.S.A - Whether Appellant has a Permanent Establishment ('PE') in India under Article 5 of the DTAA...

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. Taxability of Income in India - The receipt of IUC charges cannot be taxed as Royalty under Article 13 in India of India-France DTAA. The payment received by the...

10. 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...

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. Accrual of income in India - IATP manual clearly set out that there is no bar on member airline to provide service to non IATP Pool member and in fact, even non IATP...

13. Taxability of technical services to other airlines - DTAA with Germany - the expanded meaning of operation of aircraft included those activities in Article 8(3) through...

14. Income taxable in India - Existence of Permanent establishment (PE) - royalty/fee for technical services (FTS) - India-Germany DTAA - income from supervision services...

15. Income accrued in India - sale of shares in Flipkart - DTAA between India and Mauritius - the entire arrangement made by the applicants was with an intention to claim...