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1. Determination of Permanent Establishment - Article 5 of Indo-Mauritius DTAA – GPI project – the assessee clearly has a PE in India during the relevant years - AT

2. Permanent Establishment under Article 5 of the DTAA between India and U.S.A - Whether Appellant has a Permanent Establishment ('PE') in India under Article 5 of the DTAA...

3. 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...

4. Existence of Permanent Establishment (PE) in India or not - India UK DTAA -All the requisite conditions for attracting the mandate of Article 5(2)(k) are satisfied - ...

5. 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...

6. 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...

7. 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...

8. Indo-UK DTAA - neither under Article 5(2)(k) nor under Article 5(4) read with 5(5), the assessee has a PE in India and, therefore, the distribution fee received by the...

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

10. Income taxable In India - Taxability of compensation paid to the overseas Cricket Association for the termination of the agreement - Dependent Agent Permanent...

11. 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...

12. Income accrued in India - tratement of Income from cloud hosting services as royalty - income from cloud hosting services has erroneously held as royalty within the...

13. Establishment of Permanent Establishment (PE) in India - Onus is heavily upon the revenue to establish that that assessee’s activity had crossed the threshold period of...

14. Taxability of Income in India - The receipt of IUC charges cannot be taxed as Royalty under Article 13 in India of India-France DTAA. The payment received by the...

15. Addition on account of services rendered by the assessee to its AE in India - whether FTS under the provisions of Article 13(4)(c) of the India-UK DTAA? - the...