Home Highlights June 2012 Year 2012 This

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1. Income accrued in India - tratement of Income from cloud hosting services as royalty - income from cloud hosting services has erroneously held as royalty within the...

2. Income accrued in India - Taxability of foreign income in India - Royalty receipt - Only difference is that it relates to royalty under India- Switzerland DTAA, and...

3. The ITAT, an Appellate Tribunal, addressed the issue of whether income deemed to accrue or arise in India through royalty and fees for technical support services. The...

4. 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...

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....

6. Income deemed to accrue or arise in India - non-resident corporate entity - Taxability of royalty income received by the assessee on subscribers units from original...

7. Income accrued in India - royalty receipts - transfer of copyright in the software - India-UK DTAA - The Impugned Rulings passed by the learned AAR are set aside and it...

8. Royalty receipts for live transmission programs were not taxable as royalties under the India-Australia DTAA. The fee received for live transmission cannot be taxed as...

9. Income Taxable in India or not - Royalty/FTS income - Provision of background screening and investigation services - scope of India - USA DTAA - The Tribunal noted that...

10. 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...

11. Income taxable in India - subscription revenue for allowed ‘access’ to the database to view the videos - taxability of foreign income in India - the subscription revenue...

12. Accrual of income in India - Addition on account of royalty - receipt from Indian customer for subscription to database, sale of e-journals and membership fees -...

13. 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...

14. Income accrued in India - royalty receipt - As noted that the definition of royalty under the ITA, prior to amendment in 2012, as well as the DTAAs under consideration...

15. Income deemed to accrue or arise in India - Chargeability of receipt from domain name registration as royalty under the domestic law as well as India-USA Double Tax...