Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights April 2015 Year 2015 This

Purchase of Technical know-how - Covered under section 9(l)(vi) ...


Technical Know-How Sale u/s 9(1)(vi) IT Act Considered Royalty, Exempt from Tax Due to DTAA.

April 17, 2015

Case Laws     Income Tax     AT

Purchase of Technical know-how - Covered under section 9(l)(vi) of Income Tax Act, 1961 and treated as royalty - The Seller had sold, assigned, conveyed and transferred to assessee its entire right, title, interest and ownership in the asset - not taxable in view of DTAA - AT

View Source

 


 

You may also like:

  1. The Appellate Tribunal addressed the issue of characterizing interconnect utility charges (IUC) as 'Royalty' for TDS u/s 195 of the Income Tax Act and India-Japan DTAA....

  2. Corporate guarantee - fee for technical services (FTS) under article 13 of the India France DTAA and section 9(1)(vii) - services of corporate guarantee by the assessee...

  3. Receipts on account of “Sale of Software” - chargeability to tax as income from Royalty u/s 9(1)(vi) and Article 12 of the DTAA - India-Ireland DTAA - Since treaty...

  4. The assessee, a non-resident company incorporated in Singapore without a permanent establishment in India, received income from licensing of software to M/s. L&T Ltd....

  5. Taxability of receipts as 'fees for included services' under the India-USA Double Taxation Avoidance Agreement (DTAA). The key points are: The Assessing Officer (AO)...

  6. Royalty u/s 9(1(vi) - non resident assessee - Such payment for use of technical information and know how has to be considered as royalty both under the provisions of...

  7. Royalty/fees for technical services u/s. 9 (1) (vi)/9 (1)(vii) - payment made by SCB to assessee company does not fall within the realm of “fees for technical...

  8. The High Court examined reassessment proceedings involving income from aircraft leasing treated as royalty under the Income Tax Act and India-Ireland Double Taxation...

  9. 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...

  10. TDS u/s 195 - Payments for software licenses fees as 'Royalty' as per Section 9(1)(vi) - Unilateral amendment by the Indian Government to the term ‘royalty’ by way of...

  11. Reimbursement of salary cost treated as fees for technical services – Royalty u/s 9(1)(vii) – Indo-US DTAA - If there is a PE, then Royalty or FIS cannot be taxed under...

  12. 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...

  13. Valuation of goods - both engineering & design charges and technical know-how fees are not includible in the assessable value and Rule 9(1)(b)(iv), 9(1)(c) and 9(1)(e)...

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

  15. The assessee, a resident corporate entity providing mobile telecom services in India, challenged the taxability of bandwidth charges remitted to foreign telecom service...

 

Quick Updates:Latest Updates