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1. Income accrues or arises in India - services to MTR foods Private Limited who is located outside India - Secondment charges paid in respect of the professional services...

2. TDS u/s 195 not deducted on payment to Everest Global Inc. for software training services as source of income located outside India and payment made for services outside...

3. Taxability of salary income in India while rendering service in abroad - assessee is NRI - income accrued inside or outside India - assessee is a non-resident employee...

4. TDS disallowance for professional fees paid to non-residents without TDS deduction was deleted as the payees did not have a fixed base or permanent establishment in...

5. The appellant qualified as a non-resident in India during the previous year 2015-16. A non-resident is taxable in India only for income received/deemed to be received or...

6. The commission has been paid to non-resident outside India for services rendered outside India - where the non-resident agent operates outside India, no part of his...

7. Non-payment of Service tax - gross fee collected for Commercial Coaching and Training Services - the assessee is not entitled to deductions on account of sale of books,...

8. TDS disallowance u/s 40(a)(i) for non-deduction on overseas payments towards patent fees, reimbursement of official fees and professional fees, treating such payments as...

9. TDS u/s 195 - financial services - services were neither rendered in India nor utilized in India - explanation to Section 9(1)- though widened the scope of applicability...

10. TDS u/s 195 - payment made to non-residents towards the services rendered by them - non deduction of tds - the non-resident commission agents had rendered services...

11. TDS u/s 195 - withholding tax - payments made to the foreign firms and non-residents - rendering the services was attracting and motivating the international students...

12. TDS u/s 195 - PE in India - fees in respect of the services rendered for use of a global network and infrastructure to process card payment transactions for customers in...

13. Receipt of Fees for Technical Services (FTS) - there is no dispute that the payment made was in the nature of FTS and there is no article in DTAA for taxing the FTS...

14. Royalty Income – Finance Act, 2010 has substituted the explanation to section 9 - such income shall be included in the total income of the non-resident, whether or not...

15. 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...