International shipping profits - although the assessee company ...

Case Laws Income Tax

November 9, 2012

International shipping profits - although the assessee company had a PE in India in the year under consideration, the ships i.e. the property in respect of which shipping income was paid to the assessee company being not effectively connected with that PE - income not taxable in India - AT

View Source

← Previous Next →

International shipping profits - although the assessee company ...

Case Laws Income Tax

November 9, 2012

You may also like:

Benefit of Indo-Swiss treaty / DTAA - Although the assessee company had a PE in India in the year under consideration, the ships i.e. the property in respect of which...

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...

Income accrued in India - Benefit of India-UK Tax Treaty - Whether the assessee has PE in India and the receipts are liable to be taxed as ‘Business Profits’? - if the...

Taxability of Income in India - international taxation, permanent establishment (PE), and treaty benefits under the India-UK Double Taxation Avoidance Agreement (DTAA)....

Income deemed to accrue or arise in India - Attribution of Profit to permanent establishment (PE) in India - The Tribunal observed that while the Assessing Officer...

Income deemed to accrue or arise in India - existence of Agency PE/ Fixed Place PE - Indian-Singapore Tax Treaty - applying the legal principle to the facts emerging on...

Income accrued in India - PE - India-USA DTAA - taxability of ‘Instructor Fee’ earned from ‘GIA India Lab’ - GIA India Lab is not acting in India on behalf of the...

Income accrued in India - though the assessee had business connection, it did not have any fixed place PE or agency place PE in India, and, in the absence of any PE in...

Dependent agency PE of the assessee in India - profit attribution to the said DAPE - TP adjustments - Arm's length price - it has been brought on record that assessee...

Accrual of income in India - PE in India or not? - Agency PE - whether assessee has a business connection in India under Section 9(1)? - The ITAT Delhi ruled in favor of...

Income accrued in India - Permanent Establishment (PE) in India under Article–5 of the India–Mauritius Tax Treaty - The two companies were not exclusively working for...

Income deemed to accrue or arise in India - Collection of membership fees - We are in agreement with the claim of the assessee that amount of profit that would be...

Income deemed to accrue or arise in India - business connection in India - Permanent Establishment (PE) in India - As assessee submits that during the assessment year...

PE in India - activities of Research and development activities do not constitute a PE of the assessee in India - A plain reading of the Article 7(1) would show, that...

PE in India - Grouting activities - he establishment of PE in India is in respect of each assessment year only. Moreover, there is no bar in carrying on the activities...

Quick Updates: