Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding


  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights April 2020 Year 2020 This

Additions u/s. 9(i)(vi) - transfer of technology fee as royalty ...

Case Laws     Income Tax

April 23, 2020

Additions u/s. 9(i)(vi) - transfer of technology fee as royalty or technical fee - In the absence of any findings from the Revenue that the Acqueon Technologies Ltd Inc. USA was paid over and above the purchase price, its treatment that the impugned transaction falls u/s. 9(1)(vi) is not valid - AT

View Source

 


 

You may also like:

  1. Income accrued In India - 'Royalty' or 'Fees for Technical Services' under Section 9(l)(vi) and 9(l)(vii) - the payment made by SCB to assessee- company does not fall...

  2. Royalty/fees for technical services u/s. 9 (1) (vi)/9 (1)(vii) - payment made by SCB to assessee company does not fall within the realm of “fees for technical...

  3. TDS u/s 195 - Payments for software licenses fees as 'Royalty' as per Section 9(1)(vi) - Unilateral amendment by the Indian Government to the term ‘royalty’ by way of...

  4. Income taxable in India - Taxability of the receipts as “Royalty" - telecom services comprising of interconnectivity services - Once the situs is outside India, then in...

  5. Payments for the equipment and spare parts – Royalty u/s 9(1)(vi) - there is no transfer of rights - not taxable as royalty - HC

  6. Assessable value - Royalties/licence fees were to be paid to the foreign supplier of the equipments - For application of Rule 9(1)(e) there had to be a finding that...

  7. Corporate guarantee - fee for technical services (FTS) under article 13 of the India France DTAA and section 9(1)(vii) - services of corporate guarantee by the assessee...

  8. TDS u/s 195 - whether Legal fees paid to non-resident Attorneys constitute royalty as per India-UK DTAA and also constitute ‘Royalty’ / ‘Fees for technical services’...

  9. Income accrued in India -Treating subscription fee received from the clients in India as Royalty/FTS within the meaning of section 9(1)(vi) and 9(1)(vii) r.w. Article...

  10. Income accrued in India - Royalty u/s.9(1)(vi) - intra-group services fees - Coming to the Indo-Spain DTAA, it is axiomatic that the domestic law has not been linked...

  11. Sale of Software – Royalty – TDS u/s. 195 - the right that is transferred in the present case is the transfer of copyright including the right to make copy of software...

  12. When the royalty for transfer of right to use of computer software does not fall under Explanation 2 to sec. 9(1)(vi), but the same falls under Explanation 4 to sec....

  13. Income accrued in India - Executive search fee - neither taxable in the nature of ‘fee for technical services’ under Article 12(5)(a) or (b) nor as ‘Royalty’ under...

  14. Income deemed to accrue or arise in India - Royalty - provision of bandwidth capacity and for provision for interconnect services - The term "process" used under...

  15. Receipts from domain name registration - whether should be charged to tax as royalty as per the provisions of section 9(1)(vi) read with section 115A of the Act? - The...

 

Quick Updates:Latest Updates