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1. Income accrued in India - nature of fees for technical services - the provisions of Section 9(1)(i) are not attracted in this case as no income has accrued or arised...

2. TDS u/s.196C r.w.s. 115AC on the interest payable on FCCBs - since income in question is squarely falling under the exclusion clause of income deemed to accrue or arise...

3. Income Accrue or arise in India - FTS - the ultimate delivery of the software was outside India - Since there is no dispute that the services were rendered outside India...

4. TDS u/s 195 - As the assessee rendered "International services" outside India which required the payment in question. If this is the position, which has not even been...

5. Income taxable in India - Taxability of the receipts as “Royalty" - telecom services comprising of interconnectivity services - Once the situs is outside India, then in...

6. 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...

7. Tax withholding liability - liability to deduct tax at source u/s 196C r.w.s. 115AC on the interest payable on FCCBs - since income in question is squarely falling under...

8. Contravention of Sections 8(1) and 9(1)(f)(i) of the Foreign Exchange Regulation Act, 1973 - receiving foreign exchange payments in 1996-97 through fake export documents...

9. Income deemed to accrue or arise in India - Royalty - provision of bandwidth capacity and for provision for interconnect services - The term "process" used under...

10. Income deemed to accrue or arise in India - revenue characterization - Taxability of IUC [Interconnect utility charges] as Royalty u/s 9(1)(vi) - DTAA between India and...

11. Income deemed to accrue or arise in India - interest income - In these years, the interest income has accrued on the deposits kept by the assessees in HSBC bank, Geneva...

12. Income accrued and arise u/s.5(2) read with section 9(1)(i) - actual freight beneficiary of the vessel - DTAA - the ships operated in International Traffic and...

13. Income deemed to accrue or arise in India - salary received by the assessee in India for the services rendered in USA - though the provision under section 5(2)(a) of the...

14. Income from equipment rental sourced in India u/s 5(2) read with Section 9 of the Income Tax Act and Article 12 of India-Malaysia DTAA. DRP erred in ignoring exceptions...

15. Profit in lieu of salary for services rendered outside India - said income did not accrue or arise in India in terms of Section 6 and Section 9(1) (ii) - HC