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1. Addition u/s. 40(a)(ia) r.w. 195 - The rendition of services for earning commission cannot be of such a nature that there is a transfer of technology, in the sense it is...

2. Foreign tax credit claimed under Article 24 of India- UK DTAA read with Section 90 - assessee who is a resident of India and has derived from salary which has suffered...

3. TDS u/s 195 - Since Section 40(a)(i) as it stood in AY 2006-07 continued to discriminate in the above manner and was inconsistent with Article 24(3) of the Indo Japan...

4. Disallowance u/s 40(a)(ia) - failure to deduct TDS u/s 195 - in view of Protocol between India and Spain, the restrictive meaning of ‘Fee for Technical Services’...

5. Establishment of PE in India – service PE - Article 5 of Indo-UK DTAA – It is thus rightly held that the service PE of the assessee is established in India - AT

6. TDS u/s 195 - Disallowance of sales commission paid to foreign agents - There is no dispute that these foreign agents do not have permanent establishment in India and...

7. Income deemed to accrue or arise in India - Revenue’s suggestion is that assessee is a Limited Liability Partnership and is not liable for taxation in UK in its capacity...

8. TDS u/s 195 - professional fees paid outside India - it cannot go to the article of ‘other income’ only because of the reason that FTS article is not there in the Double...

9. Tax credit under article 23(2) of India Japan Double Taxation Avoidance Agreement ['Indo Japanese tax treaty'] - on the peculiarities of Indo Japanese tax treaty...

10. Income accrued in India - Royalty u/s.9(1)(vi) - intra-group services fees - Coming to the Indo-Spain DTAA, it is axiomatic that the domestic law has not been linked...

11. Liability to pay interest upon finalization of provisional assessment prior to insertion of sub-section (3) in Section 18 of the Customs Act, 1962 - The CESTAT analyzed...

12. Addition on account of services rendered by the assessee to its AE in India - whether FTS under the provisions of Article 13(4)(c) of the India-UK DTAA? - the...

13. Income deemed to accrue or arise in India - definition of ‘interest’ as provided under article 12 of the India –U.K. DTAA - the amount received by the assessee is in the...

14. Taxability of income in India - Interest income on income tax refund - As referring to relevant Article 11 of Indo-US DTAA with regard to interest it can be concluded...

15. TDS u/s 195 - assessee in default - withholding of tax - A.O in treating the assessee as an assessee in default for not deducting tax at source on remittances made to...