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1. The assessee, a resident Indian company engaged in manufacturing boiler pressure parts and engineering plants, paid ocean freight charges to a non-resident Korean...

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. Liability to pay interest u/s 234B - In the light of legal position as it existed for the relevant Assessment Years prior to insertion of proviso to Section 209(1) of...

4. Assessee employed by Indian entity but sent on long-term international assignment to Singapore. Salary received in India for administrative reasons, but employment...

5. 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...

6. 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...

7. TDS u/s 195 - Disallowance u/s 40(a)(i) - the said income in the hands of non-resident has to be considered in the light of the provisions of DTAA between India and the...

8. No doubt, if the person (payer) who had to make payments to the non-resident had defaulted in deducting the tax at source from such payments, the non- resident is not...

9. TDS disallowance u/s 40(a)(i) for non-deduction on overseas payments towards patent fees, reimbursement of official fees and professional fees, treating such payments as...

10. TDS u/s 195 - Payment chargeable to tax in India or not DTAA with USA - DRP held that the services provided by the non-residents were received and utilised by the...

11. Income deemed to accrue or arise in India - revenue characterization - Taxability of IUC [Interconnect utility charges] as Royalty u/s 9(1)(vi) - DTAA between India and...

12. Where not only the bonds were raised outside India, but the interest payments were also made to non-residents outside India from a bank account held by the assessee...

13. TDS u/s 195 - payments by resident Indian end-user to non-resident computer software manufacturers/suppliers - payment for software licenses not royalty under Article 12...

14. Rate of TDS - Non-availability of PAN - Benefit of treaty - in case of payments made to non-residents, the assessee was entitled to deduct taxes at source at the rates...

15. The commission has been paid to non-resident outside India for services rendered outside India - where the non-resident agent operates outside India, no part of his...