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1. Income taxable in India - payments received from its India customers on account of Centralized Services - Fee for Technical Services - Fee for included services - The...

2. 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...

3. Corporate guarantee - fee for technical services (FTS) under article 13 of the India France DTAA and section 9(1)(vii) - services of corporate guarantee by the assessee...

4. TDS u/s 195 - professional services - Fees for Technical Services (FTS) - the definition of “Fees for Technical Services” has to be given a restrictive meaning similar...

5. 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...

6. Fee for technical services is for the services rendered by the assessee and service tax collected by the assessee from the recipient of services on such fee would not...

7. Income accrued In India - 'Royalty' or 'Fees for Technical Services' under Section 9(l)(vi) and 9(l)(vii) - the payment made by SCB to assessee- company does not fall...

8. Income deemed to accrue or arise in India - treatment of "Commission income" and receipts from "Subscription fee" - Assessee in publishing business receiving...

9. Income deemed to accrue or arise in India - Fee for Technical Services (FTS)/ Fee for Included Services (FIS) - the services provided by the assessee under the marketing...

10. Roaming charges paid by telecom operators to other operators constitute "fees for technical services" u/s 194J, attracting TDS obligation, as human intervention and...

11. Income accrued or deemend to accrue in India - Fees for technical services' under Article 12(5)(a) of the India-Netherlands tax treaty - as providing of access to CRS,...

12. Doctrine of mutuality - satisfaction of three tests - Fees for technical services - assessee is an association (Verein), established in Switzerland, with its members...

13. Income accrued in India - Fee for Technical Services [FTS] - 'make available’ - the marketing and sales services, operations and standardization services do not satisfy...

14. This case deals with the valuation of imported goods, specifically whether license fees and management fees paid to related parties should be included in the assessable...

15. TDS u/s 195 - Disallowance of management fee paid by invoking the provisions of section 40(a)(i) - whether payment of management fees cannot be regarded as fees for...