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Income Tax - Highlights / Catch Notes

Home Highlights April 2015 Year 2015 This

Taxability of advertisement revenue & subscription revenue - Tax ...

Income Tax

April 21, 2015

Taxability of advertisement revenue & subscription revenue - Tax Treaty between India and USA - Appellant has a PE in India, both Advertisement and Subscription revenues constitute business income of the Appellant in India and that 10% of the Advertisement and Subscription revenues be treated as taxable income of the appellant in India. - AT

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  1. Taxability of income in India - Income attributable to India - income of advertisement and subscription revenue - Permanent Establishment (PE) - business connection -...

  2. Characterizing subscription revenue received - Indian–United Kingdom Tax Treaty - PE in India - not only the subscription fee is in the nature of royalty but the...

  3. Taxability of capital gain arising on sale of shares under the treaty provisions - AO and DRP have rejected assessee’s claim by holding that assessee being a mere paper...

  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. Service rendered in India - “salaries” - for a period not exceeding 183 days - taxability in India - remunerations in view of the treaty, taxable at Denmark and not in India - HC

  6. Levy of penalty u/s 76 and 78 of the Finance Act, 1994 - taxability of Sale of Space or Time for Advertisement - it is a case of bonafide mistake - no penalty - AT

  7. Taxability of income - Characterization of receipts - software sub-licence fee - the income in dispute, since can be classified under other Articles of the tax treaty,...

  8. Income taxable in India - subscription revenue for allowed ‘access’ to the database to view the videos - taxability of foreign income in India - the subscription revenue...

  9. Taxability of global income - sale of shares - taxability of long term capital gain - Undisputedly, the shares sold by the assessee in the year under consideration were...

  10. Deletion of addition of advertisement expenses – AO erred in holding that the advertisement expenses as deferred revenue expenses is not valid in the eyes of law - AT

 

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