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Income Tax - Highlights / Catch Notes

Home Highlights December 2022 Year 2022 This

Income accrued in India - subscription/distribution revenue ...

Income Tax

December 7, 2022

Income accrued in India - subscription/distribution revenue earned by the assessee - royalty receipt - the issue, whether the assessee had a PE in India in these two assessment years is purely academic in the nature, as, the entire income has been offered to tax by Indian entity - AT

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  1. Income accrued in India - subscription/distribution revenue derived by the assessee as assessable to tax as royalty - the amount received cannot be brought to tax in...

  2. Income accued in India - taxability of subscription charges received by the assessee as “Royalty” - the income earned by way of CAS fee are squarely applicable to the...

  3. Income accrued in India -Treating subscription fee received from the clients in India as Royalty/FTS within the meaning of section 9(1)(vi) and 9(1)(vii) r.w. Article...

  4. Income accrue in India - PE in India - nature of income - the distribution revenue earned by the appellant-assessee cannot be taxed as royalty albeit as a business...

  5. Revenue earned from supply of software and rendering of maintenance and professional services to customers located in Sri Lanka and Middle East as “Royalty/ FTS/ FIS” -...

  6. Accrual of income in India - Addition on account of royalty - receipt from Indian customer for subscription to database, sale of e-journals and membership fees -...

  7. Income accrued in India - royalty or fees for technical services - subscription fees receipts for online data base - assessee only gets access to a copyrighted article...

  8. Revenue receipt or capital receipt - there is no justification to treat the receipt of life membership subscription of the magazine differently other than the income receipt.

  9. Income taxable in India - subscription revenue for allowed ‘access’ to the database to view the videos - taxability of foreign income in India - the subscription revenue...

  10. Income accrued in India - interest income and commitment fees earned by DZ Bank from its Indian clients - PE in India - Once entire interest revenues earned in India in...

 

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