Scope of Article 12(3)(a) of DTAA between India and Belguim – ...

India-Belgium DTAA Article 12(3)(a) defines software payments as for copyrighted articles, not copyright itself.

March 25, 2014

Case Laws Income Tax AT

Scope of Article 12(3)(a) of DTAA between India and Belguim – the payment for software is for a copyrighted article and not copyright per se is not covered by the scope of payment for copyright - AT

View Source

← Previous Next →

Scope of Article 12(3)(a) of DTAA between India and Belguim – ...

India-Belgium DTAA Article 12(3)(a) defines software payments as for copyrighted articles, not copyright itself.

March 25, 2014

Case Laws Income Tax AT

You may also like:

TDS u/s 195 - payments by resident Indian end-user to non-resident computer software manufacturers/suppliers - payment for software licenses not royalty under Article 12...

Taxability of income in India - income from the sale of Software licenses subscription - India - Japan DTAA - CIT(A) held that the consideration received by the assessee...

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...

Accrual of income in India - Royalty receipts - taxation of revenue from online database of text journal and books as royalty income u/Article 12 of India US DTAA - The...

The assessee earned income from professional services rendered in foreign countries like Japan, Nepal, and Singapore. The Income Tax Appellate Tribunal (ITAT) examined...

TDS u/s 195 - royalty - purchase of software - copyrighted articles - payments made by it to various suppliers of six countries did not amount to royalty within the...

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...

TDS u/s 195 - DTAA with Uganda - professional services - the services received by the assessee from these three persons is covered by article 14 and therefore, the same...

The ITAT ruled in favor of the taxpayer, determining that fabrication charges received could not be treated as "fees for technical services" under Article 12(4)(a) of...

The assessee company made payments for IT service charges to a foreign entity without deducting tax at source (TDS) u/s 195. The Assessing Officer treated these expenses...

TDS u/s 195 - Royalty - import of software - The payments in question is made by the user of the Red Hat Subscriptions for the purpose of availing convenient...

Accrual of income in India - rendering leadership training to employees of SAPL cannot be said as rendering managerial services so as to fall outside the ambit of fees...

Income accrued in India - the sale proceeds cannot be characterized as 'Royalty' as per Article 12 of the India- Ireland DTAA, as the same is towards the use of...

Fees for technical services (FTS) - India France DTAA - claiming the benefit of the restricted definition under India USA DTAA - Since the assessee has been found not to...

The Delhi High Court examined whether guarantee charges received by an appellant from its Indian subsidiaries are taxable in India. The Tribunal found that the...

Quick Updates: