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1. Income taxable in India or not - FTS/FIS - payments received by the assessee from its Indian customers on account of Centralized Services - absence of PE in India - The...

2. Taxability in India - amount received by the assessee from offshore supplies of plants and equipments - PE in India or not? - The Tribunal questioned the differential...

3. Taxability of Income in India - international taxation, permanent establishment (PE), and treaty benefits under the India-UK Double Taxation Avoidance Agreement (DTAA)....

4. 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...

5. 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...

6. PE in India - India-Spain DTAA - business profit carried out through PE - Services rendered from outside India - there is no Permanent Establishments during the relevant...

7. 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...

8. Existence of Fixed Place Permanent Establishment (“Fixed Place PE”) and Supervisory Permanent Establishment (“Supervisory PE”) - India-Japan DTAA - Merely providing...

9. Income accrued in India - Article for taxability of FTS under the India Thailand Treaty - Existence of PE in India - The assessee company has no Permanent Establishment...

10. 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...

11. 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...

12. Income deemed to accrue or arise in India - business connection in India - Permanent Establishment (PE) in India - As assessee submits that during the assessment year...

13. 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...

14. TDS u/s 195 - payments made by the assessee for marketing services to the US Company as taxable in India as FTS [Fee for Technical Services] - US Company does not have...

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