Indo-UK DTAA - neither under Article 5(2)(k) nor under Article ...

Case Laws Income Tax

September 19, 2015

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 assessee can not be held to be taxable in India. - AT

View Source

← Previous Next →

Indo-UK DTAA - neither under Article 5(2)(k) nor under Article ...

Case Laws Income Tax

September 19, 2015

You may also like:

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

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...

Foreign tax credit claimed under Article 24 of India- UK DTAA read with Section 90 - assessee who is a resident of India and has derived from salary which has suffered...

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...

Short term capital gain - sale of units of mutual funds - Article 13(4)/13(5) of DTAA of India-UAE - the gains arising from transfer of units of mutual funds should not...

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...

Interest on refund of income tax received by the PE of the assessee - taxability - applicability of Article 12(5) or Article 12(2) of DTAA between India and France - not...

No agency PE in India under Article-5(4) of the India China DTAA of the non-resident entity-i.e. ZPMC - AT

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 - ...

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

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...

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...

Tax credit under article 23(2) of India Japan Double Taxation Avoidance Agreement ['Indo Japanese tax treaty'] - on the peculiarities of Indo Japanese tax treaty...

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...

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...

Quick Updates: