Income taxable in India - payments received from its India ...

Case Laws Income Tax

May 15, 2024

Income taxable in India - payments received from its India customers on account of Centralized Services - Fee for Technical Services - Fee for included services - The Tribunal, after examining the agreements and services provided, concluded that the services were related to publicity, marketing, and advertisement, not technical or consultancy services. Therefore, they did not fall under the definition of FIS as per Article 12(4)(a) or (b) of the DTAA. - The Tribunal reaffirmed that the services provided were not ancillary or subsidiary to the application or enjoyment of any right, property, or information for which a royalty payment was made, thus not qualifying as FIS under Article 12(4)(a).

View Source

← Previous Next →

Income taxable in India - payments received from its India ...

Case Laws Income Tax

May 15, 2024

You may also like:

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...

Income deemed to accrue or arise in India - Taxability of “cloud service fee” received by the assessee from customers in India - the payments received by the assessee...

Remuneration received directly remitted from foreign to the NRE account - accrual of income - salary received in India is taxable in India in terms of section 5(2)(a) - AT

Income accrued in India - Centralized services fee received - royalty or fee for technical services The payments received were rightly held by the Tribunal, to be in the...

Taxability of an amount received from supply of drawings and designs - Accrual of income in India - Once the income from supply of plant and equipment is held to be not...

Income deemed to accrue or arise in India - Payments received by the assessee from it Indian customers on account of Centralized Services - Fee for Technical Services as...

Income taxable in India - Management Support Charges - the fee received by the assessee under the Centralized Services Agreement cannot be treated as FIS either under...

Source of Cash deposited into the Bank Account - Agricultural income - advances received from customers in land transactions - CIT(A) ought to have considered the...

Income Taxable in India - Salary - foreign assignment allowance received by the assessee for the services rendered outside India - the foreign assignment allowance that...

Income deemed to accrue or arise in India - non-resident corporate entity - Taxability of royalty income received by the assessee on subscribers units from original...

Taxability of income in India - income from the sale of Software licenses subscription - India - Japan DTAA - CIT(A) held that the consideration received by the assessee...

Income accrued in India - Salary income - services rendered outside India - AO objected that evidence was not produced for receiving the foreign allowance outside India...

Income deemed to accrue or arise in India - The centralised services income, by a reasonable measure, outstrips the royalty income. Thus, rather than centralised service...

Income deemed to accrue or arise in India - amount received by the assessee on account of Time Charter of its ship as “royalty‟ and taxing the same u/s 9(1)(vi) -...

Accrual of income in India - royalty income - supply of software - absence of PE of the assessee in India - The Tribunal held that, the payments received by the assessee...

Quick Updates: