Income accrued in India - Permanent Establishment (PE) - the ...

Income from Taj India Not Taxable in India: No Agency Permanent Establishment Under DTAA Article 5(4), Confirms ITAT and High Court.

March 13, 2020

Case Laws Income Tax HC

Income accrued in India - Permanent Establishment (PE) - the distribution income earned by the assessee cannot be taxed in India because Taj India does not constitute an agency Permanent Establishment under the terms of Article 5(4) of the DTAA - Order of ITAT confirmed - HC

View Source

← Previous Next →

Income accrued in India - Permanent Establishment (PE) - the ...

Income from Taj India Not Taxable in India: No Agency Permanent Establishment Under DTAA Article 5(4), Confirms ITAT and High Court.

March 13, 2020

Case Laws Income Tax HC

You may also like:

Income taxable in India - PE in India - Once we hold that in the light of the present legal position, existence of dependent agency permanent establishment in wholly tax...

Permanent Establishment in India - advertisement revenue - India-Mauritius DTAA - foreign company / Non-resident - Taj India cannot be held to be a DAPE of the assessee...

Permanent Establishment under Article 5 of the DTAA between India and U.S.A - Whether Appellant has a Permanent Establishment ('PE') in India under Article 5 of the DTAA...

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...

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...

Income taxable In India - Taxability of compensation paid to the overseas Cricket Association for the termination of the agreement - Dependent Agent Permanent...

The HC held that the Liaison Office (LO) of the US company engaged in Money Transfer Services did not constitute a Permanent Establishment (PE) in India under the...

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...

No agency PE in India under Article-5(4) of the India China DTAA of the non-resident entity-i.e. ZPMC - AT

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...

Clubbing of income of Non-resident and Permanent Establishment (PE) - Levy of surcharge at 5% as against assessee’s claim of 2% - The royalty and Fee for Technical...

TDS u/s 195 - Disallowance of sales commission paid to foreign agents - There is no dispute that these foreign agents do not have permanent establishment in India and...

Income accrued in India - Shipping income earned in India - India Singapore DTAA - income is exempt in the singapore - AO has made an attempt to deny the benefit of...

Income accrued in India - Permanent Establishment (PE) in India under Article–5 of the India–Mauritius Tax Treaty - The two companies were not exclusively working for...

The assessee's income earned in the USA is taxable in India. The tie-breaker test under Article 4 of the India-US DTAA is not applicable, as the assessee's centre of...

Quick Updates: