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1. Income accrued or deemend to accrue in India - Fees for technical services' under Article 12(5)(a) of the India-Netherlands tax treaty - as providing of access to CRS,...

2. Income accrued in India - interest income on loans in the form of suppliers credit given to Indian parties - As alleged that the Indian parties from whom the assessee...

3. Taxability of foreign income in India - use of Virtual Voice Network (VVN) - Income deemed to accrue or arise in India - PE in India - The grounds of the Revenue were...

4. Taxability of income in India - Taxability as Royalty or FTS - The tribunal systematically addressed the taxability of each type of service. It concluded that the...

5. TDS u/s 195 - disallowance u/s. 40(a)(i) for non deduction of TDS on payment to non-resident which is in nature of FTS(Fee for Technical Service) - beneficial provisions...

6. Business income - activities carried out by the assessee company by rendering technical handling services to the other airlines in India and has certainly connected with...

7. Income deemed to accrue or arise in India - PE in India - employees of the assessee were present in India for rendering services for a period aggregating to only 13 days...

8. Income deemed to accrue or arise in India - Fee for Technical Services (FTS)/ Fee for Included Services (FIS) - the services provided by the assessee under the marketing...

9. Income chargeable to tax as FIS in India - Fee for included service - The e-publishing work in the nature of editorial services comprising of page composition, language...

10. Income taxable in India - Existence of Permanent establishment (PE) - royalty/fee for technical services (FTS) - India-Germany DTAA - income from supervision services...

11. 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...

12. TDS liability u/s 195 - Income accrued in India - fees for technical services - thus Solutions provided by the Applicant without human intervention cannot be treated as...

13. Import of service - Technical Inspection & Certification Services - reverse charge - merely because appellant receiving service in India does not mean service was partly...

14. Taxability as Fee for Included Service (FIS) u/A 12 of India-USA DTAA - As per Example 7 of the Memorandum of Understanding to India-USA DTAA, a receipt cannot be...

15. Taxability of foreign income in India - business connection’ in India or not? - subscription services - ITAT came to the factual finding that the arrangement between...