Even if the assessee's case is not covered by Article 8, the ...

Assessee's Business Profits Exempt from Indian Tax Due to No Permanent Establishment Under DTAA Articles 7 and 5.

February 24, 2018

Case Laws Income Tax AT

Even if the assessee's case is not covered by Article 8, the business profits would not be chargeable to Indian tax as it does not carry on business in India through a permanent establishment (an agency PE) as per articles 7 and 5 of the DTAA - AT

View Source

← Previous Next →

Even if the assessee's case is not covered by Article 8, the ...

Assessee's Business Profits Exempt from Indian Tax Due to No Permanent Establishment Under DTAA Articles 7 and 5.

February 24, 2018

Case Laws Income Tax AT

You may also like:

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...

TDS u/s 195 - assessee in default - payroll services rendered by IBM Philippines to the assessee - as per Article 7(1) of Indian Philippines DTAA, the business profits...

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...

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...

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...

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...

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...

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...

Taxability of Income in India - international taxation, permanent establishment (PE), and treaty benefits under the India-UK Double Taxation Avoidance Agreement (DTAA)....

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

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...

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...

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...

ITAT ruled against establishing a dependent agent Permanent Establishment (PE) of foreign entity (Japan) through its Indian subsidiary under India-Japan DTAA Article 5....

The Appellate Tribunal addressed the issue of characterizing interconnect utility charges (IUC) as 'Royalty' for TDS u/s 195 of the Income Tax Act and India-Japan DTAA....

Quick Updates: