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1. Income deemed to accrue or arise in India - interest income - In these years, the interest income has accrued on the deposits kept by the assessees in HSBC bank, Geneva...

2. TDS u/s 195 - As the assessee rendered "International services" outside India which required the payment in question. If this is the position, which has not even been...

3. Income accrues or arises or deemed to accrue or arise in India - Unexplained foreign income - residential status of the assessee - The Tribunal upheld the CIT(A)'s...

4. TDS u/s.196C r.w.s. 115AC on the interest payable on FCCBs - since income in question is squarely falling under the exclusion clause of income deemed to accrue or arise...

5. Income Accrue or arise in India - FTS - the ultimate delivery of the software was outside India - Since there is no dispute that the services were rendered outside India...

6. Income accrue or arise in India - Revenue from playing of the matches in India - DTAA - Payments made to the Non- Resident Sports Associations in the present case...

7. Income accrue or arise, or deemed to accrue or arise in India - It was admitted that the applicant conducts seismic surveys offshore for which it requires seismic...

8. Income received or deemed to be received or accrued or arose or deemed to be accrued or arose in India - Income by way of brokerage and commission - assessee maintains a...

9. Additions towards cash seized at airport - Tax should be charged in the relevant assessment year in which it has been received or deemed to be received/accrues or arises...

10. Tax withholding liability - liability to deduct tax at source u/s 196C r.w.s. 115AC on the interest payable on FCCBs - since income in question is squarely falling under...

11. Addition on the ground of balance appearing in HSBC Bank Account, Geneva undisclosed - Nothing has been brought on record in “reasons recorded” or there is any material...

12. TDS u/s 195 - disallowance u/s 40(a)(i) - commission paid to non-resident outside India for the services rendered outside India will not fall in the category of the...

13. Accrual of income - accrue or arise - Although, earning of income is a necessary pre-requisite for accrual of income, mere earning of income without right to receive the...

14. Income accrued in India - permanent establishment (PE) - Withholding of tax in India - vessel engaged in seismic survey at high sea - The sum paid by the applicant to...

15. Accrual of income - Addition on account of amount kept in Escrow Account - slump sale - The word “accruing” and arising are used to contradistinguish the word “receive”....