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Income Tax Case Laws - Section: 9

Home Case Index Income Tax Sections List
Cases for Section: 9
Showing 1 to 15 of 1254 Records
 
  • 2016 (8) TMI 809 - ITAT DELHI

    Royalty income - India-Italy DTAA - technical agreement - existence of PE in India - Held that - In substances neither there is any material about the requirement of the services by the recipient of the services nor provision of such services, if any... ... ...


  • 2016 (8) TMI 166 - DELHI HIGH COURT

    TDS u/s 195 - withholding of tax - payments made/ to be made to Steria France under the Management Services Agreement - whether the payment made by Steria (India) for the management services provided by Steria France will not be taxable in India in t... ... ...


  • 2016 (8) TMI 47 - ITAT DELHI

    TDS u/s 195 - Royalty Income chargeable to tax - payment for purchase of shrink wrapped readymade software from salesforce.com, Singapore - taxability in India - Held that - The said payment does not fall with the purview of royalty as well as Articl... ... ...


  • 2016 (7) TMI 1094 - DELHI HIGH COURT

    Taxability in India - intellectual property rights in trademarks, brands, logos etc. - AAR - whether the receipt arising to the applicant, from the transfer of its right, title and interest in and to the trademarks, Foster s Brand Intellectual Proper... ... ...


  • 2016 (7) TMI 744 - ITAT MUMBAI

    Taxability of income in India - PE in India - business connection in India - Chargeability of income under section 44B - India-Singapore DTAA - Held that - As decided in assessee company s own case for assessment year 2009-10 we hold that income of t... ... ...


  • 2016 (7) TMI 1043 - ITAT MUMBAI

    Taxability of royalty income - nature of income - PE in India - DTAA India USA - Held that - The authorities below have proceeded on the assumption that the assessee company is the same entity which has entered into agreements in 1991 and is continui... ... ...


  • 2016 (7) TMI 712 - ITAT MUMBAI

    Guarantee commission receipt - taxability in India - Held that - As decided in assessee;s own case for Assessment Year 2009-10 guarantee commission earned by the assessee from the two associate Indian concerns cannot be held to be taxable in India. -... ... ...


  • 2016 (7) TMI 698 - ITAT MUMBAI

    PE in India - Indo-US Treaty - addition made being a profit margin of 5 of the sale made by the assessee in India - Held that - As decided in assessee s own case for the assessment years 2004-05, 2005-06 & 2008- 09 the assessee did not have PE in... ... ...


  • 2016 (7) TMI 762 - DELHI HIGH COURT

    Sale of pre-packaged software - royalty or fee for technical services - whether not taxable as business income? - Held that - It is not in dispute that Article 12 (3) of the Double Taxation Avoidance Agreement ( DTAA ) between India and the United St... ... ...


  • 2016 (7) TMI 562 - ITAT MUMBAI

    TDS u/s 195 - non deduction of tax at source on payment to Centre for Investment and Business Advisory, Indonesia as fees for technical services (FTS) under section 9(1)(vii) - Disallowance of expenses under section 40(a)(ia) - India-Indonesia DTAA -... ... ...


  • 2016 (7) TMI 567 - ITAT MUMBAI

    TDS u/s 195 - professional fees paid outside India without deduction of tax at source - disallowance u/s 40(a)(i) - PE existence - Held that - From the details on record there is no material to establish that any technical knowledge, skill, etc. have... ... ...


  • 2016 (7) TMI 580 - ITAT KOLKATA

    TDS u/s 195 - whether the payments made by the assessee to its foreign subsidiaries would fall under the ambit of fees for technical services as per the DTAA - PE in India - Held that - We find that as per Article 7 of UK and Singapore Treaty, in the... ... ...


  • 2016 (7) TMI 460 - ITAT MUMBAI

    Taxability in India - capital gain arising on the sale of immovable property in Colombo, Sri Lanka - DTAA - Held that - The income of the assessee earned on capital gains on sale of immovable property situated in Sri Lanka during relevant previous ye... ... ...


  • 2016 (8) TMI 504 - ITAT MUMBAI

    TDS u/s 195 - income from Indian operation - whether the assessee did had an agency PE in the form of Taj India within the meaning of Article 5(4) of the India-Mauritius-DTAA? - Held that - An agent is deemed to be a PE of a foreign enterprise, if he... ... ...


  • 2016 (8) TMI 552 - ITAT CHENNAI

    TDS u/s 195 - disallowance made against payment made to Consequence Australia Pty. Ltd., Australia, for purchase of database by treating it as payment made for obtaining technical services which comes within the scope of section 9 consequently attrac... ... ...


 
   
 
 
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