Home Highlights November 2013 Year 2013 This

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1. 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...

2. Income accrued in India - Article for taxability of FTS under the India Thailand Treaty - Existence of PE in India - The assessee company has no Permanent Establishment...

3. The assessee, a foreign airline company and tax resident of the USA, engaged in the business of operating aircraft in international traffic, obtained approval from DGCA...

4. 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...

5. Income deemed to accrue or arise in India - PE in India - employees of the assessee were present in India for rendering services for a period aggregating to only 13 days...

6. Income deemed or accrue or arise in India - liaison office - Permanent Establishment (PE) - Revenue though vehemently submitted that liaison office was negotiating price...

7. Income deemed to accrue or arise in India - royalty income - permanent establishment (PE) in India - Each project site did not exceed threshold limit of 183 days. - The...

8. Income accrued in India - Permanent Establishment (PE) in India under Article–5 of the India–Mauritius Tax Treaty - The two companies were not exclusively working for...

9. Income deemed to accrue or arise in India - interest income - In these years, the interest income has accrued on the deposits kept by the assessees in HSBC bank, Geneva...

10. Income accrued in India - PE in India - computers installed at the premises of the subscriber constitute a PE of the assessee in India in terms of Article 5 (1) of...

11. Income accrued in India - Benefit of India-UK Tax Treaty - Whether the assessee has PE in India and the receipts are liable to be taxed as ‘Business Profits’? - if the...

12. Income deemed to accrue or arise in India - existence of Agency PE/ Fixed Place PE - Indian-Singapore Tax Treaty - applying the legal principle to the facts emerging on...

13. Income accrued in India - PE - India-USA DTAA - taxability of ‘Instructor Fee’ earned from ‘GIA India Lab’ - GIA India Lab is not acting in India on behalf of the...

14. Income accrued in India - permanent establishment (PE) - Withholding of tax in India - vessel engaged in seismic survey at high sea - The sum paid by the applicant to...

15. Applicability of Article 7 of the Double Taxation Avoidance Agreement (DTAA) between India and the United Arab Emirates regarding the taxation of profits attributed to a...