Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights January 2013 Year 2013 This

Presumptive Taxation – India US DTAA - No Permanent ...


High Court Affirms No Tax for Foreign Entities Without Permanent Establishment Under India-US DTAA and Section 44BB.

January 28, 2013

Case Laws     Income Tax     HC

Presumptive Taxation – India US DTAA - No Permanent establishment (PE) in India – not taxable even it received any remuneration in connection with any matter provided in Section 44BB. - HC

View Source

 


 

You may also like:

  1. TDS disallowance for professional fees paid to non-residents without TDS deduction was deleted as the payees did not have a fixed base or permanent establishment in...

  2. 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...

  3. TDS u/s 195 - Disallowance u/s 40(a)(i) - the said income in the hands of non-resident has to be considered in the light of the provisions of DTAA between India and the...

  4. Interconnectivity usage charges received by a foreign entity from an Indian entity cannot be considered as Fees for Technical Services (FTS) under domestic law or the...

  5. The assessee, a foreign airline company and tax resident of the USA, engaged in the business of operating aircraft in international traffic, obtained approval from DGCA...

  6. Reverse charge mechanism (RCM) - Liability of recipient of service to pay service tax - deemed services - The Appellants have received goods from entities located...

  7. DTAC between India and Singapore - permanent establishment - When a business cannot be carried on exclusively in so far as it relates to customers in India without...

  8. The assessee, a Limited Liability Company (LLC) under US tax laws, was denied treaty benefits under the India-USA Double Taxation Avoidance Agreement (DTAA) by the...

  9. 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...

  10. Income taxable in India or not - Taxation of Technical Collaboration Fees @ 10% u/s. 9(1)(vii) r.w.s 115A(1)(b) - The Appellate Tribunal considered the arguments...

  11. TDS u/s 195 - Disallowance of commission expenditure paid to foreign agents for non-deduction of tax - Assessee has consistently denied that they do not have any...

  12. TDS u/s 195 - disallowance of design expenses u/s.40(a)(i) - it seems that the amount paid by the assessee to the foreign party as fee for technical services is subject...

  13. 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...

  14. 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...

  15. ITAT adjudicated a tax dispute involving consultancy income from a non-resident entity without permanent establishment (PE) in India. The tribunal examined treaty...

 

Quick Updates:Latest Updates