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1. Income accrued in India - interest income on loans in the form of suppliers credit given to Indian parties - As alleged that the Indian parties from whom the assessee...

2. Clubbing of income of Non-resident and Permanent Establishment (PE) - Levy of surcharge at 5% as against assessee’s claim of 2% - The royalty and Fee for Technical...

3. Income deemed to accrue or arise in India - offshore supply of design and engineering inextricably linked with manufacturing and supply of equipment, not taxable as Fees...

4. 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...

5. TDS disallowance for professional fees paid to non-residents without TDS deduction was deleted as the payees did not have a fixed base or permanent establishment in...

6. The assessee, a foreign company, earned network transportation fees from its Indian associated enterprise (AE), Damco India Private Limited (DIPL). The Assessing Officer...

7. Club or Association Service - Admission Fee, Membership Fee, Establishment Expenses, collected by the appellant from its members - amount retained for earning ‘carbon...

8. Levy of service tax - The appellant is not liable to pay service tax on Export Pass fee, Import Pass fee, Permit fee, Excise Staff Salary and overtime allowances/charges...

9. Income taxable in India - Existence of Permanent establishment (PE) - royalty/fee for technical services (FTS) - India-Germany DTAA - income from supervision services...

10. Taxability in India - amount received by the assessee from offshore supplies of plants and equipments - PE in India or not? - The Tribunal questioned the differential...

11. Fees for Technical Services – AO only undertook the issue of stay of technicians in India cannot be considered for examining the 'permanent establishment' of assessee in...

12. 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...

13. 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...

14. Income taxable in India or not - Taxation of Technical Collaboration Fees @ 10% u/s. 9(1)(vii) r.w.s 115A(1)(b) - The Appellate Tribunal considered the arguments...

15. Income deemed to accrue or arise in India - business connection in India - Permanent Establishment (PE) in India - As assessee submits that during the assessment year...