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 January 2014 Year 2014 This

Status of Assessee – Taxability of Profits - Technically, CIT ...


Tax Authority Reviews Permanent Establishment Status and Profit Taxability; Urges Lower Authorities to Examine Relevant Articles Thoroughly.

January 9, 2014

Case Laws     Income Tax     AT

Status of Assessee – Taxability of Profits - Technically, CIT (A) has decided the issue relating to PE - but, in order to have a complete holistic view, it is necessary that all the relevant Articles dealing with the issue are considered by the lower authorities before arriving at any conclusion - AT

View Source

 


 

You may also like:

  1. Income taxable in India or not - Taxation of Technical Collaboration Fees @ 10% u/s. 9(1)(vii) r.w.s 115A(1)(b) - The Appellate Tribunal considered the arguments...

  2. The High Court considered the validity of reassessment proceedings regarding the taxability of income without Permanent Establishment in India under India-Japan DTAA,...

  3. Permanent Establishment (PE) in India - attribution of profit to the PE - Revenue authorities have not brought any material on record to demonstrate that the activities...

  4. Review petition - Levy of penalty u/s 271(1)(c) - Tribunal sustaining the levy without providing an opportunity of hearing - Review applicant had paid entire tax amount...

  5. 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...

  6. Income deemed to accrue or arise in India - Attribution of Profit to permanent establishment (PE) in India - The Tribunal observed that while the Assessing Officer...

  7. The Income Tax Appellate Tribunal held that the payments received by the assessee, a foreign resident without a permanent establishment in India, for providing offshore...

  8. The Supreme Court analyzed the applicability of the Tamil Nadu Industrial Establishments (Conferment of Permanent Status to Workmen) Act, 1981 to a Corporation and its...

  9. Taxability of interest on income tax refund received - PE in India or not? - whether shall be taxable as business income under Article 7 of India-France DTAA as against...

  10. PE in India - India-Spain DTAA - business profit carried out through PE - Services rendered from outside India - there is no Permanent Establishments during the relevant...

  11. ITAT ruled in favor of local authority operating in Magadi town, Karnataka, reversing lower authorities' denial of exemptions under Sections 11 and 12. The authority's...

  12. 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...

  13. Taxability of Income in India - international taxation, permanent establishment (PE), and treaty benefits under the India-UK Double Taxation Avoidance Agreement (DTAA)....

  14. Clubbing of income of Non-resident and Permanent Establishment (PE) - Levy of surcharge at 5% as against assessee’s claim of 2% - The royalty and Fee for Technical...

  15. Income accrued in India - taxation of interest income - assessee is a company incorporated and fiscally domiciled in the Republic of Japan - For interplay of Article...

 

Quick Updates:Latest Updates