Income accruing or arising in India - dividend on IDR - The ...

Case Laws Income Tax

January 28, 2023

Income accruing or arising in India - dividend on IDR - The Tribunal, in case Morgan Stanley Mauritius Co Ltd. [2021 (5) TMI 968 - ITAT MUMBAI], after examining the transaction concluded that the taxability of IDR dividends fail in the light of India – Mauritius DTAA –Article 22. - AT

View Source

← Previous Next →

Income accruing or arising in India - dividend on IDR - The ...

Case Laws Income Tax

January 28, 2023

You may also like:

Income accrues or arises or deemed to accrue or arise in India - Unexplained foreign income - residential status of the assessee - The Tribunal upheld the CIT(A)'s...

Income Accrue or arise in India - FTS - the ultimate delivery of the software was outside India - Since there is no dispute that the services were rendered outside India...

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...

Income accrue or arise in India - Revenue from playing of the matches in India - DTAA - Payments made to the Non- Resident Sports Associations in the present case...

Income accrued in India - nature of fees for technical services - the provisions of Section 9(1)(i) are not attracted in this case as no income has accrued or arised...

TDS u/s.196C r.w.s. 115AC on the interest payable on FCCBs - since income in question is squarely falling under the exclusion clause of income deemed to accrue or arise...

TDS u/s 195 - As the assessee rendered "International services" outside India which required the payment in question. If this is the position, which has not even been...

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...

Duty of AO to Guide the Assessee - Considering the specific facts on record that the assessee is non resident the amount which the ld. AO has taxed is earned and sourced...

Tax withholding liability - liability to deduct tax at source u/s 196C r.w.s. 115AC on the interest payable on FCCBs - since income in question is squarely falling under...

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...

TDS u/s 195 - disallowance u/s 40(a)(i) - commission paid to non-resident outside India for the services rendered outside India will not fall in the category of the...

Income deemed to accrue or arise in India - addition on account of LTCG to be taxed u/s 112 - Scope of holding Tax Residency Certificate of Mauritius (TRC) - The...

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 - non-resident corporate entity - Taxability of royalty income received by the assessee on subscribers units from original...

Quick Updates: