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1. Accrual of income in India - PE in India or not? - use or right to use brand name/trade mark - the receipts cannot be treated as royalty under Article 12(3)(a) of the...

2. Income accrued in India - Taxability of foreign income in India - Royalty receipt - Only difference is that it relates to royalty under India- Switzerland DTAA, and...

3. Income accrued in India -Treating subscription fee received from the clients in India as Royalty/FTS within the meaning of section 9(1)(vi) and 9(1)(vii) r.w. Article...

4. India and Saudi Arabia DTAC - share of the annual operations and maintenance charges - cannot be treated as fees for technical services - AAR

5. Denying the benefit u/s 91 - Tax Credit - Income accrue in India - assessee being “Resident but not Ordinarily Resident" is not a “Resident in India” - persons who are...

6. 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...

7. 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...

8. 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...

9. 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...

10. Levy of tax on interest income - Status of the assessee - Resident but not ordinarily resident - NRI Account - Provisions of Section 5(2) are also not applicable as the...

11. All the evidences establish that assessee was non-resident and earned salary outside India which was received by him outside India and therefore was not taxable in India - AT

12. Income accrued in India - Fee for Technical/Included Services - whether the amount received by the assessee for various services, commonly known as centralized services,...

13. Residence in India - Residential status - Status of the assessee as “Resident” of India - calculation of days of stay in India - inclusion of date of arrival in counting...

14. Income taxable in India - Management Support Charges - the fee received by the assessee under the Centralized Services Agreement cannot be treated as FIS either under...

15. Assessment of dividend income - hostile discrimination between a resident assessee and a non-resident assessee - Non-residents can be treated differently for the reason...