DTAA between India and USA - professional service for ...

Income Tax

June 20, 2012

DTAA between India and USA - professional service for consultancy rendered outside India and not for supply of scientific, technical, industrial or commercial knowledge or information. - there was no liability to deduct TDS - AT

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DTAA between India and USA - professional service for ...

Income Tax

June 20, 2012

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Income accrues or arises in India - services to MTR foods Private Limited who is located outside India - Secondment charges paid in respect of the professional services...

Taxability as Fee for Included Service (FIS) u/A 12 of India-USA DTAA - As per Example 7 of the Memorandum of Understanding to India-USA DTAA, a receipt cannot be...

Income accrued in India - Article 15(1) of India-Austria DTAA agreement - if services are rendered outside India such income would not be taxable in India - the salary...

Income deemed to accrue or arise in India - salary received by the assessee in India for the services rendered in USA - though the provision under section 5(2)(a) of the...

Income accrued in India - professional legal services provided before a foreign court - it cannot be brought to tax as FIS under Article 12 of the India-USA DTAA,...

Income accrued in India - Salary income - services rendered outside India - AO objected that evidence was not produced for receiving the foreign allowance outside India...

Fees for technical services (FTS) - India France DTAA - claiming the benefit of the restricted definition under India USA DTAA - Since the assessee has been found not to...

Place of supply - supplier of service and recipient of service are located in India - immovable property located outside India - The applicant who is the supplier of...

Export of services - various issues - provided outside India - Delivered Outside India - Services rendered in India - Used in India etc. - AT

Export of services or not - services rendered for foreign companies (which do not have any business place/agency in India) in India - services provided in respect of...

Place of supply of services. - In order to examine whether Section 13(3)(b) of the IGST Act is applicable, it is necessary to identify the service provider and the...

Levy of service tax - applicability of Reverse Charge Mechanism - Business Auxiliary Service - he services have been provided by the foreign agents to the foreign site...

The commission has been paid to non-resident outside India for services rendered outside India - where the non-resident agent operates outside India, no part of his...

Territorial Jurisdiction - Levy of GST - Both the transactions of Sale and purchase are done outside India - the applicant is involved in supply of books, purchased from...

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...

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