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1. Income taxable in India or not - FTS/FIS - payments received by the assessee from its Indian customers on account of Centralized Services - absence of PE in India - The...

2. 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...

3. Taxability of income in India - income from the sale of Software licenses subscription - India - Japan DTAA - CIT(A) held that the consideration received by the assessee...

4. Income accrued in India - Shipping income earned in India - India Singapore DTAA - income is exempt in the singapore - AO has made an attempt to deny the benefit of...

5. 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...

6. TDS u/s 195 - Disallowance of sales commission paid to foreign agents - There is no dispute that these foreign agents do not have permanent establishment in India and...

7. 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...

8. Income accrues or arises in India - services to MTR foods Private Limited who is located outside India - Secondment charges paid in respect of the professional services...

9. Receipt of Fees for Technical Services (FTS) - there is no dispute that the payment made was in the nature of FTS and there is no article in DTAA for taxing the FTS...

10. 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...

11. Income taxable in India - payments made to the law firm in Poland - nature of Fee for technical services under section 9(1) (vii) of the Act as well as Article 13 of...

12. Income accrued or deemed to accrue in India - marketing and advertising rights that have been granted under the MAA [Marketing and Advertising Agreement'] - rights under...

13. Applicability of Article 7 of the Double Taxation Avoidance Agreement (DTAA) between India and the United Arab Emirates regarding the taxation of profits attributed to a...

14. Disallowance of business loss of discontinued business: Deduction for expenditure incurred towards professional charges, consultancy charges, ESI arrears, and bank...

15. Withholding Tax u/s 195 - CIT(A) examined the taxability of the non-resident under the provisions of the DTAA between India and Italy. The AO, in the Remand Report, had...