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

2. Management Service Agreement ("MSA") to its subsidiaries - the majority of the services are technical in nature and the remaining one are in the area of consultancy....

3. TDS on payment made for Internet services i.e. leased line benefits/broadband services - the expression 'technical service' would have reference to only technical...

4. TDS U/S 194J - internet services, i.e. leased line benefits/broadband services - whether in the nature of technical services - the payment for uses of internet of the...

5. TDS U/S 194J - payment for providing SMS services as well as technical support services - There is no technical or professional services - No TDS liability - HC

6. TDS on certain foreign payments - reimbursements of expenses - independent professional service - The case involves a dispute over the classification of services...

7. Nature of activity - service or not - business support services or not - Installation of fixed facilities in the premise of customer/buyer - uninterrupted supply of gas...

8. TDS on roaming charges paid to other service providers - the roaming process between participating company cannot be termed as technical services and, therefore, no TDS...

9. 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...

10. Disallowance u/s. 40(a)(ia) - TDS u/s 195 - no PE - Article 12 of DTAA between India and USA - Royalties and Fees for Included Services - payments for subscription fees...

11. 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,...

12. TDS u/s 195 - Scope of “make available” - The concept of make available which requires that fruits of services should remain unavailable to the service recipients in...

13. TDS u/s 195 - Disallowance of management fee paid by invoking the provisions of section 40(a)(i) - whether payment of management fees cannot be regarded as fees for...

14. FTS - TDS - the expression ‘technical services’ takes colour from the expressions ‘managerial services’ and ‘consultancy services’ which necessarily involve a human...

15. Income deemed to accrue or arise in India - receipts of subscription fees - The ITAT had found that it did not involve the transfer of copyright or the provision of...