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Income Tax - Highlights / Catch Notes

Home Highlights June 2016 Year 2016 This

'Royalty' receipt - Revenue was not able to show that the ...

Income Tax

June 3, 2016

'Royalty' receipt - Revenue was not able to show that the Petitioner had a PE in India, the income earned by the Petitioner from the contract with IOCL cannot be brought to tax in India in terms of Article 7 of the DTAA - Decision of AAR reversed - HC

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  1. Taxable Income in India or not - Royalty receipt - PE in India or not? - amount received towards Marketing Contribution, Priority Club receipts, Reservation...

  2. Revenue earned from supply of software and rendering of maintenance and professional services to customers located in Sri Lanka and Middle East as “Royalty/ FTS/ FIS” -...

  3. Accrual of income in India - existence of PE - business profits attributable to the PE - Entire profits from supply of equipments and software cannot be attributed to...

  4. Income accrued in India - interest income and commitment fees earned by DZ Bank from its Indian clients - PE in India - Once entire interest revenues earned in India in...

  5. PE in India - India-Spain DTAA - business profit carried out through PE - Services rendered from outside India - there is no Permanent Establishments during the relevant...

  6. Income accrued in India - subscription/distribution revenue earned by the assessee - royalty receipt - the issue, whether the assessee had a PE in India in these two...

  7. Taxability in India - amount received by the assessee from offshore supplies of plants and equipments - PE in India or not? - The Tribunal questioned the differential...

  8. Income accrued in India - Taxability as Royalty income - the income earned by the assessee from sale of software, either directly to the customers in India or through...

  9. Taxability of Income in India - The receipt of IUC charges cannot be taxed as Royalty under Article 13 in India of India-France DTAA. The payment received by the...

  10. Income deemed to accrue or arise in India - royalty income - permanent establishment (PE) in India - Each project site did not exceed threshold limit of 183 days. - The...

 

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