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 July 2018 Year 2018 This

TDS u/s 195 - Since there is no transfer of technology or use of ...


Payments for Affiliation Not Classified as 'Royalty' u/s 195: No Tech Transfer Involved, Says IT Act & DTAA.

July 6, 2018

Case Laws     Income Tax     AT

TDS u/s 195 - Since there is no transfer of technology or use of any technology and payment is only simply for affiliation, the above amount cannot be considered as ‘royalty’ either under the provisions of Income Tax Act or under the provisions of DTAA.

View Source

 


 

You may also like:

  1. TDS u/s 195 - payments by resident Indian end-user to non-resident computer software manufacturers/suppliers - payment for software licenses not royalty under Article 12...

  2. 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....

  3. TDS u/s 195 - royalty payments or not - Consideration for advertisement is paid to the overseas bank account of Non-resident - the payments made by the assessee the...

  4. TDS u/s 195 - use of logo - license fee payment without deducting TDS SUPIMA, USA - Agreement clearly shows that the payment is made by the assessee to use the Logo of...

  5. The Appellate Tribunal addressed the issue of Tax Deducted at Source (TDS) under section 195, specifically disallowance under section 40(a)(i) for payments labeled as...

  6. TDS u/s 195 - DTAA between India and US - disallowance u/s 40(a)(ia) - the assessee did not acquire any right from Amazon for which the payments have been made but the...

  7. Sale of Software – Royalty – TDS u/s. 195 - the right that is transferred in the present case is the transfer of copyright including the right to make copy of software...

  8. Disallowance of expenses u/s.40(a)(ia) - Non deduction of TDS u/s 195 - at the time of payment made by the assessee to non-residents, there was an ambiguity in the...

  9. Royalty income payments made by the assessee for obtaining computer software were not liable to be taxed in India as royalty u/s 9(1)(6). The amounts paid by resident...

  10. Income taxable in India - TDS u/s 195 - Royalty or Business Profit - the process involved in providing the services to the end users / customers is not “secret” but a...

  11. TDS u/s 195 - payments made to its Non-Resident Telecom Operators (NTOs) for provision of bandwidth capacity and provision of interconnect services - The Tribunal...

  12. TDS disallowance u/s 40(a)(i) for non-deduction on overseas payments towards patent fees, reimbursement of official fees and professional fees, treating such payments as...

  13. TDS u/s 195 - payment for time charter higher charges are Royalty u/s 9(1)(vi) - The Tribunal held that the payments made by Jaisu Shipping Co. Pvt. Ltd. for hiring...

  14. TDS u/s 195 - Royalty - the amounts paid by resident Indian endusers/ distributors to non-resident computer software manufacturers/suppliers, as consideration for the...

  15. Income taxable in India - Royalty or FTS - PE in India or not? - Assessment of payments made by Google India Pvt. Ltd. (Payer) to Google Ireland Limited (payee) for...

 

Quick Updates:Latest Updates