Home Highlights August 2012 Year 2012 This

You may also like:

1. Fees for Technical Services [FTS] - Receipt of Cost-to-cost reimbursements on account of secondment of employees - seconded personnel are employees of EY India firms -...

2. Claims of amount paid for employees taken on Secondment - Revenue attribution - AO on one hand had held the secondment agreement to be not a genuine agreement but on the...

3. Income of salary earned by the assessee in USA to tax in India - ‘resident alien’ in USA - There is nothing before us to contradict the findings of the learned CIT(A) in...

4. 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...

5. Rectification u/s 154 - taxation of salary income earned in USA - The appeal before the Appellate Tribunal involved various issues related to the taxation of income...

6. TP Adjustment - US Transactions non US Transactions - scope of MAP agreement - It would be better to refer to the settlement arrived between the competent authority of...

7. 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...

8. 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...

9. Salary earned in USA - dual resident India & USA - Article 4(2) of DTAA with USA - if on the basis test of tiebreaker rule for ‘Centre of Vital Interests’ it is found...

10. Income deemed to accrue or arise in India - interest income - In these years, the interest income has accrued on the deposits kept by the assessees in HSBC bank, Geneva...

11. 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,...

12. Rectification of mistake u/s 154 - subject income being inadvertently shown under the wrong head - Taxability of income in India - The benefit of Article 121 of...

13. A citizen of a foreign State, resident in India, being an employee of a foreign company or a citizen of India working in India can open foreign currency account with a...

14. Income accrues or arises in India - services to MTR foods Private Limited who is located outside India - Secondment charges paid in respect of the professional services...

15. Classification of services - employee of the parent company, Nektar USA, was sent to India on a secondment to work as a full time Managing Director of the Indian company...