Home Highlights February 2014 Year 2014 This

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1. 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...

2. Taxability of salary income in India while rendering service in abroad - assessee is NRI - income accrued inside or outside India - assessee is a non-resident employee...

3. The commission has been paid to non-resident outside India for services rendered outside India - where the non-resident agent operates outside India, no part of his...

4. Non-payment of Service tax - gross fee collected for Commercial Coaching and Training Services - the assessee is not entitled to deductions on account of sale of books,...

5. TDS u/s 195 - financial services - services were neither rendered in India nor utilized in India - explanation to Section 9(1)- though widened the scope of applicability...

6. TDS u/s 195 - payment made to non-residents towards the services rendered by them - non deduction of tds - the non-resident commission agents had rendered services...

7. Receipt of Fees for Technical Services (FTS) - there is no dispute that the payment made was in the nature of FTS and there is no article in DTAA for taxing the FTS...

8. Royalty Income – Finance Act, 2010 has substituted the explanation to section 9 - such income shall be included in the total income of the non-resident, whether or not...

9. TDS u/s 195 - withholding tax - payments made to the foreign firms and non-residents - rendering the services was attracting and motivating the international students...

10. TDS u/s 195 - PE in India - fees in respect of the services rendered for use of a global network and infrastructure to process card payment transactions for customers in...

11. Income taxable in India - Taxability of the receipts as “Royalty" - telecom services comprising of interconnectivity services - Once the situs is outside India, then in...

12. Liability of pay service tax - the non-residents provided services to the appellant outside India - in respect of services provided by the non-residents, the appellant...

13. TDS u/s 195 - Disallowance u/s 40(a)(ia) - non-deduction of TDS on payment of management fees - It is not even the allegation of the revenue that the non-residents had...

14. TDS u/s 195 - export commission paid to foreign parties - the payment of commission are made to non-resident overseas agents who have no PE or business activities in...

15. TDS liability u/s 195 - Income of non-resident agents cannot be considered to accrue or arise or deemed to be received in India when the services rendered by the...