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1. Income accrued in India - Royalty u/s.9(1)(vi) - intra-group services fees - Coming to the Indo-Spain DTAA, it is axiomatic that the domestic law has not been linked...

2. Accrual of income in India - royalty receipt - transmission of ‘live feed’ - Income from the transmission of 'live feed' does not fall within the ambit of 'royalty'...

3. Income taxable in India - royalty receipts - copyright - Light to broadcast “Live events” - when the agreements clearly bifurcate the consideration paid towards Live and...

4. Benefit of DTAA - Article 13(6) can be pressed into service only in the case when the existence of PE of non-resident is not in dispute. In this case the assessee has...

5. Treaty benefits - ‘gains from alienation of shares' - taxability or otherwise of capital gain from sale of equity shares under Article 13(4) of India-Mauritius DTAA -...

6. Income deemed to accrue or arise in India - Royalty receipt - Voice Interconnect Services (IUC) - the installation and operation of sophisticated equipments are with the...

7. Classification of composite supply - works contract service - Explanation to Serial No 3(vi) of said NT, 'business' shall not include any activity or transaction...

8. Short term capital gain - sale of units of mutual funds - Article 13(4)/13(5) of DTAA of India-UAE - the gains arising from transfer of units of mutual funds should not...

9. TDS u/s 194J – the broadcast/live telecast is not a work within the definition of 2(y) of the Copyright Act and also that broadcast/ live telecast doesn’t fall within...

10. Accrual of income in India - Royalty receipts - taxation of revenue from online database of text journal and books as royalty income u/Article 12 of India US DTAA - The...

11. Receipts on account of “Sale of Software” - chargeability to tax as income from Royalty u/s 9(1)(vi) and Article 12 of the DTAA - India-Ireland DTAA - Since treaty...

12. 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...

13. Income accrued in India - receipts of the assessee from sale of software - In view of Section 90(2) of the Income Tax Act, the assessee opts for Double Taxation...

14. TDS u/s 195 - Payment of royalty - disallowance u/s 40(a)(i) - What the appellant gets is only a copyrighted article to use the product for its internal business purpose...

15. Income deemed to accrue or arise in India - Royalty Income - conducting research activities - Article 13(3)of India-UK DTAA shows that the transaction shall fall under...