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1. The expenditure incurred by the assessee towards royalty and fee for technical assistance in pursuance of the licence agreement were revenue expenditure and not capital...

2. Income deemed to accrue or arise in India - amounts received by the assessee from its Indian subsidiary towards IT and SAP charges - the services rendered under IT and...

3. TDS u/s 195 - liability u/s 201 and 201(1A) - Fees for Technical Services (FTS) or not - Distribution Agreement between the assessee and the foreign company - The...

4. DOUBLE TAXATION AGREEMENT - AGREEMENT FOR EXCHANGE OF INFORMATION AND ASSISTANCE IN COLLECTION WITH RESPECT TO TAXES WITH FOREIGN COUNTRIES - LIBERIA. - Notification

5. Double taxation Agreement - Agreement between the Government of the Republic of India and the Government of Jersey for the Exchange of Information and Assistance in...

6. Valuation of imported goods - includibility - Before adding the royalty amounts to the value of imported components, it is necessary for the department to examine both...

7. Fees for technical services (FTS) - Though, the departmental authorities have alleged that the make available condition stands satisfied, however, no material has been...

8. Disallowance of payments made for royalty and technical know-how received - Accepted Most appropriate method for benchmarking the manufacturing segment as TNNM -...

9. Treatment to acquiring technical know - revenue v/s capital expenditure - expenditure incurred for grant of License which accords ‘access’ to technical knowledge, as...

10. Non-Stamping of arbitration agreements - Agreements which are not stamped or are inadequately stamped are inadmissible in evidence under Section 35 of the Stamp Act....

11. Arbitration - The jurisdiction clause of an agreement, the absence of words like “alone”, “only”, “exclusive” or “exclusive jurisdiction” is neither decisive nor does it...

12. Double taxation agreement - Agreement with foreign countries or specified territories - Notified 'Specified Territory' - Notification

13. Taxability of Fees for technical services (FTS) - In Article–13(4)(c) of the India–UK tax treaty the words “or consists of the development and transfer of a technical...

14. Valuation - import of goods - neither the fees paid under the Licence Agreement nor under the Basic Engineering, Training and Technical Services Agreement related to the...

15. TDS liability - FTS - the consideration paid under the secondment agreement was not “fees for technical services” because the fact that the seconded employee was...