The information / knowledge available to the assessee was made ...

Case Laws Income Tax

September 26, 2013

The information / knowledge available to the assessee was made through a licence; consequently, it is covered under the definition of “royalty“ under the domestic law under section 19(1)(iv) and (vi) along with article 13(3) of the Double Taxation Avoidance Agreement with the U.K- AT

View Source

← Previous Next →

The information / knowledge available to the assessee was made ...

Case Laws Income Tax

September 26, 2013

You may also like:

TDS u/s 195 - Scope of “make available” - The concept of make available which requires that fruits of services should remain unavailable to the service recipients in...

The Income Tax Appellate Tribunal (ITAT) held that the consultancy services rendered by the assessee, such as organizational strategy, talent acquisition, rewards and...

Challenge AAR ruling - Income taxable in India or not? - TDS liability u/s 195 - whether payments to SIPCL for BSS under the Cost Contribution Arrangement ("CCA") - The...

Income deemed to accrue or arise in India - MOU to the India US DTAA elaborates on the concept of "make available" - Merely providing commercial information through a...

Fees for technical services (FTS) - Though, the departmental authorities have alleged that the make available condition stands satisfied, however, no material has been...

TDS u/s 195 - Disallowance u/s 40(a)(ia) - non-deduction of TDS on payment of management fees - It is not even the allegation of the revenue that the non-residents had...

The key points in the legal document are: Software licensing amounts do not qualify as Fees for Included Services under Article 12(4)(b) of the India-US DTAA, as the...

Taxability of receipts as 'fees for included services' under the India-USA Double Taxation Avoidance Agreement (DTAA). The key points are: The Assessing Officer (AO)...

Addition on account of services rendered by the assessee to its AE in India - whether FTS under the provisions of Article 13(4)(c) of the India-UK DTAA? - the...

Classification of supplies - supply of goods or supply of services? - software licenses supplied by the applicant - the goods which are supplied by the applicant cannot...

Classification of supply - supply of goods or supply of services - software license - the Explanatory Notes to the Scheme of Classification of Services stipulates that...

Disallowance of bad debts as claimed u/s 36(1)(viia) - deduction claimed @10% of aggregate average advances - AO is directed to make relevant enquires and verifications...

The case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

Income from commercial information or output generated by accessing the assessee's software does not constitute Fees for Included Services (FIS) under Article 12(4)(b)...

The Appellate Tribunal examined the validity of the reassessment notice issued u/s 148 and the consequent order passed u/s 147 regarding the addition made by the...

Quick Updates: