Income accrued in India - professional legal services provided ...

Legal Services Abroad Not Taxed as FIS Under Article 12, India-USA DTAA; Excluded from Income Tax Act Section 9(1)(vii).

July 2, 2019

Case Laws Income Tax AT

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, because there is no make available of any particular knowledge or skill to ONGC before the courts which can enable ONGC to represent its case in future - legal services cannot be treated as FTS as it is a professional services which is outside the scope of Section 9(1)(vii)

View Source

← Previous Next →

Income accrued in India - professional legal services provided ...

Legal Services Abroad Not Taxed as FIS Under Article 12, India-USA DTAA; Excluded from Income Tax Act Section 9(1)(vii).

July 2, 2019

Case Laws Income Tax AT

You may also like:

Taxability of interest on income tax refund received - PE in India or not? - whether shall be taxable as business income under Article 7 of India-France DTAA as against...

The assessee received amounts from Indian customers for supplying software updates, patches, and on-call support services. The issue pertained to taxability of these...

The assessee earned income from professional services rendered in foreign countries like Japan, Nepal, and Singapore. The Income Tax Appellate Tribunal (ITAT) examined...

Income deemed to accrue or arise in India - Fee for Technical Services (FTS)/ Fee for Included Services (FIS) - the services provided by the assessee under the marketing...

ITAT ruled in favor of the assessee, determining tax liability for services provided to Indian customers under India-USA DTAA. The tribunal held that income from domain...

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)...

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...

Income taxable in India - payments received from its India customers on account of Centralized Services - Fee for Technical Services - Fee for included services - The...

Income deemed to accrue or arise in India - residential status of the assessee under the India-USA DTAA. Assessee stayed in India for more than 183 days, considered a...

The assessee's income received from Indian customers as Fee for Technical Services (FTS)/Fee for Included Services (FIS) u/s 9(1)(vii) of the Act and Article 12(4) of...

Income taxable India - taxability of receipts from consultancy services and reimbursement of expenses - characterizing receipts as Fee for Included Services (“FIS”)...

The ITAT ruled that the Indian entity (RIC) was not a dependent agent permanent establishment (DAPE) under Article 5 of the USA-India DTAA, following its previous...

Income accrued in India - tratement of Income from cloud hosting services as royalty - income from cloud hosting services has erroneously held as royalty within the...

The case revolves around the taxation of income earned by the assessee from licensing software to Indian customers under the India-USA Double Taxation Avoidance...

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...

Quick Updates: