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1. 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...

2. Foreign tax credit claimed under Article 24 of India- UK DTAA read with Section 90 - assessee who is a resident of India and has derived from salary which has suffered...

3. Levy of Surcharge and cess - to be computed over the rate of tax as per DTAA or not - Article 12 read with Article 2 of the tax treaty makes it clear that the rate of...

4. Short term capital gain - sale of units of mutual funds - Article 13(4)/13(5) of DTAA of India-UAE - the gains arising from transfer of units of mutual funds should not...

5. Income accrued in India - Shipping income earned in India - India Singapore DTAA - income is exempt in the singapore - AO has made an attempt to deny the benefit of...

6. Applicability of surcharge and cess on DTAA rate of tax - as per DTAA between India and Netherlands, the income tax including surcharge shall not exceed 10% - A.O....

7. Taxability of income in India - Interest income on income tax refund - As referring to relevant Article 11 of Indo-US DTAA with regard to interest it can be concluded...

8. Income deemed to accrue or arise in India - residential status of the assessee under the India-USA DTAA. Assessee stayed in India for more than 183 days, considered a...

9. Accrual of income in India - period of stay in India - salary received by the assessee from his foreign employer - DTAA between India and USA - Revenue contended that,...

10. 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...

11. Income accrued or deemed to accrue in India - As the design services were inextricably connected with setting up of the plant and were rendered through this PE, the...

12. This case deals with the accrual of income in India from exploration activities and the determination of whether the assessee has a Permanent Establishment (PE) in India...

13. Applicability of Article 8 vis-a-vis Article 24 of DTAA - DTAA between India and Singapore - shipping income - Article 24 only envisages territorial and jurisdictional...

14. Income accrued in India - dividend income - DDT is levy on the dividend distributed by the payer company, being an additional tax is covered by the definition of ‘Tax’...

15. Income accrued in India - Taxability of foreign income in India - Royalty receipt - Only difference is that it relates to royalty under India- Switzerland DTAA, and...