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 August 2023 Year 2023 This

Income taxable/attribuable in India - attributed 15% of the ...


Supreme Court Confirms 15% Income Attributable to India, Citing Galileo Rule and Travelport Case; Revenue Appeal Dismissed.

August 3, 2023

Case Laws     Income Tax     SC

Income taxable/attribuable in India - attributed 15% of the assessee’s income to India - applicability of the Galileo rule[2009 (2) TMI 497 - DELHI HIGH COURT] - Galileo Nederland BV [supra] has now merged with the order of this Court in Travelport [2023 (5) TMI 227 - SUPREME COURT] filed by the Revenue before this Court. - Revenue appeal dismissed - SC

View Source

 


 

You may also like:

  1. Attribution of 15% Revenue to the PE in India - invocation of Rule 27 for challenging the decision of the CIT (A) - Since no guidelines are available as to how much...

  2. Taxability of income in India - Income attributable to India - income of advertisement and subscription revenue - Permanent Establishment (PE) - business connection -...

  3. Assessee employed by Indian entity but sent on long-term international assignment to Singapore. Salary received in India for administrative reasons, but employment...

  4. Income taxable in India - Income attributable to the operations carried out in India - Article 7 of DTAA with USA, may not really go to the rescue of the Revenue for the...

  5. The issue pertains to whether the amounts received as sales commission by a non-resident assessee are in the nature of fees for included services, and whether such...

  6. 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...

  7. Income accrued in India - Article 15(1) of India-Austria DTAA agreement - if services are rendered outside India such income would not be taxable in India - the salary...

  8. Profit attributable to India - an assessee whose business operations are not exclusively carried out in India, the amount of income which will be deemed to accrue or...

  9. Taxability of salary income earned by non-residents from Indian companies. In this Judgement, it was determined that under Section 9(1)(ii) of the Income Tax Act, salary...

  10. Income taxability in India - even if for the sake of argument, it is assumed that MFPM has a business connection in India, it cannot be said that the income is deemed to...

  11. TDS u/s 195 not deducted on payment to Everest Global Inc. for software training services as source of income located outside India and payment made for services outside...

  12. Salary earned outside India from employment in Korea not taxable in India as per Article 15(1) of India-Korea DTAA since services rendered outside India. Salary offered...

  13. Income deemed to accrue or arise in India - Collection of membership fees - We are in agreement with the claim of the assessee that amount of profit that would be...

  14. 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...

  15. Income deemed to accrue or arise in India - income attributable to India - As we have held that the ATC’s are not the DAPE of the assessee, therefore, the addition i.e...

 

Quick Updates:Latest Updates