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1. 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...

2. 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...

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. 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...

5. 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...

6. Article 8 of DTAA between India and Germany - Reference to DRP - Pooling/slot arrangements - Permanent Establishment (PE) - Feeder services - operation of ships in...

7. 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...

8. Accrual of income in India - period of stay in India - salary received by the assessee from his foreign employer - DTAA between India and USA - Revenue contended that,...

9. Income accrued in India - interest income and commitment fees earned by DZ Bank from its Indian clients - PE in India - Once entire interest revenues earned in India in...

10. Applicability of Article 8 visavis Article 24 of DTAA - income assessable to tax at Singapore on the basis of accrual or remittance - The contention of the revenue that...

11. 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...

12. Taxability of income in India - income from the sale of Software licenses subscription - India - Japan DTAA - CIT(A) held that the consideration received by the assessee...

13. 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...

14. TDS u/s 195 - taxability of the freight income earned by the principal relatable to transportation of cargo and goods - Denial of exemption under Article 8 of DTAA...

15. 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...