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 May 2023 Year 2023 This

Income deemed to accrue or arise in India - licensing of ...

Income Tax

May 12, 2023

Income deemed to accrue or arise in India - licensing of software products of Microsoft in the Territory of India by the Respondent was not taxable in India as Royalty under Section 9(1)(vi) read with Article 12 of the Indo US DTAA - this is not Royalty liable to be taxed in India - Revenue appeal dismissed - SC

View Source

 


 

You may also like:

  1. Nature of activity - sale or service - The appellant procured COA/stickers/labels under a Microsoft OEM Customer License Agreement, affixing them to Thin Clients...

  2. Income deemed to accrue or arise in India - fee for grant of software license cannot be taxed in India. Since we have held that the subject transaction of receipt of...

  3. 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...

  4. Royalty receipts - income deemed to accrue or arise in India - assessee had sold software licenses to its associated enterprises and to other Indian customers - The ITAT...

  5. Classification of services - Information Technology Software Service or Franchise Service? - licence fee paid to SAP AG, Germany, for grant of non-exclusive licence to...

  6. Withdrawal of exemption from service tax on cross border B2C OIDAR services provided online/electronically from a non-taxable territory to consumers in taxable territory in India

  7. 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...

  8. Income deemed to accrue or arise in India - Clause wise scheme and arrangement of various activities - Section 9

  9. Income deemed to accrue or arise in India - Section 9 of the Income-tax Act, 1961 as amended

  10. Sale of software / download of software - (a) If the software is to be supplied by way of electronic download of software, which involves provision of service and hence...

 

Quick Updates:Latest Updates