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1. The ITAT considered the taxability of income in India as Fees for Included Service (FIS) or Fees for Technical Services (FTS) received by a non-resident corporate entity...

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

3. Assessment u/s 144C - Royalty receipt - income from distribution of software licenses and providing support services - AO has not followed the directions of the DRP and...

4. 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...

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

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. Classification of services - Information Technology Software Service or Franchise Service? - licence fee paid to SAP AG, Germany, for grant of non-exclusive licence to...

8. The case revolves around the taxation of income earned by the assessee from licensing software to Indian customers under the India-USA Double Taxation Avoidance...

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

10. 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...

11. Accrual of income in India - Royalty / FTS - the software maintenance fees, consulting charges and training fees which are incidental to software license fee, assumes...

12. Income accrued in India - royalty and Fees for Technical Services - literary work - The grant of license to use the software cannot be construed as granting a right to...

13. The income deemed to accrue or arise in India, including reimbursement received for SAP Software and Microsoft License fees, was held to be taxable as royalty receipts...

14. The assessee received amounts from Indian customers for supplying software updates, patches, and on-call support services. The issue pertained to taxability of these...

15. Accrual of income in India - PE in India or not? - use or right to use brand name/trade mark - the receipts cannot be treated as royalty under Article 12(3)(a) of the...