Income deemed to accrue or arise in India - addition on account ...

Income Tax

March 7, 2024

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 Tribunal allowed the appeal, holding that investments made prior to April 1, 2017, are grandfathered under the India-Mauritius DTAA and not subject to capital gains taxation in India. The Tribunal followed the principles laid out in the case of Bid Services Division (Mauritius) Ltd. vs. Authority for Advance Rulings and other relevant CBDT circulars and press releases, confirming that the assessee is entitled to the DTAA benefits.

View Source

← Previous Next →

Income deemed to accrue or arise in India - addition on account ...

Income Tax

March 7, 2024

You may also like:

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 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...

Addition on the ground of balance appearing in HSBC Bank Account, Geneva undisclosed - Nothing has been brought on record in “reasons recorded” or there is any material...

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 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...

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 deemed to accrue or arise in India - fee for grant of software license cannot be taxed in India. Since we have held that the subject transaction of receipt of...

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...

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 - income attributable to India - As we have held that the ATC’s are not the DAPE of the assessee, therefore, the addition i.e...

Accrual of income - Addition on account of amount kept in Escrow Account - slump sale - The word “accruing” and arising are used to contradistinguish the word “receive”....

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...

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...

Addition u/s 69A/68 - The assessee has earned the commission income from Mauritius and having Non-Resident status under section 6 of the Income Tax Act. The assessee has...

Quick Updates: