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1. 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...

2. 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...

3. 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...

4. Export of Business auxiliary service - The appellant promoted the business of such foreign companies in India and as a consideration for this service, the appellant...

5. The assessee had artificially split the composite contract to avoid establishment of a permanent establishment (PE) in India and tax payment. The Assessing Officer (AO)...

6. 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...

7. Establishment of PE in India – service PE - Article 5 of Indo-UK DTAA – It is thus rightly held that the service PE of the assessee is established in India - AT

8. 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...

9. Income accrued in India - Article for taxability of FTS under the India Thailand Treaty - Existence of PE in India - The assessee company has no Permanent Establishment...

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

11. Income accrued in India - permanent establishment (PE) - Withholding of tax in India - vessel engaged in seismic survey at high sea - The sum paid by the applicant to...

12. TDS u/s 195 - referral fee paid to a foreign concern, in USA for introducing clients - not in the nature of Managerial services,Technical services or Consultancy fees -...

13. Accrual of income in India - PE in India or not? - Agency PE - whether assessee has a business connection in India under Section 9(1)? - The ITAT Delhi ruled in favor of...

14. 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...

15. Income accrued in India - PE - India-USA DTAA - taxability of ‘Instructor Fee’ earned from ‘GIA India Lab’ - GIA India Lab is not acting in India on behalf of the...