Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights September 2018 Year 2018 This

Disallowance u/s 40(a)(i) - technical on-call assistance charges ...


Taxpayer's On-Call Assistance Charges to AE Not Taxable in India Under DTAA, Section 195 Inapplicable.

September 29, 2018

Case Laws     Income Tax     AT

Disallowance u/s 40(a)(i) - technical on-call assistance charges paid by assessee to its AE - Revenue received by AE in view of services rendered to assessee’s customer is not taxable in India as per Article 12 (4) of India US DTAA, applicability of section 195 of the Act is not possible.

View Source

 


 

You may also like:

  1. Transfer pricing adjustment - No interest having been charged by the assessee to the non-AE outstandings, its transaction of outstanding receivables with AE without...

  2. Levy of GST - Place of supply - Tax imposed on exhibition services received by the petitioner in non-taxable territory from the person located in non-taxable territory...

  3. 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...

  4. The charges collected by the appellant from customers towards statutory obligations like electricity charges, water charges, and legal fees are reimbursable expenses and...

  5. The Delhi High Court examined whether guarantee charges received by an appellant from its Indian subsidiaries are taxable in India. The Tribunal found that the...

  6. Amount received is in the nature of royalty or not - taxability in India - Section 9(1)(xi) - activity of providing access to its internet by which it provides a gateway...

  7. TPA - Adjustment of interest for delayed realization of sale from AE - when the assessee is not charging any interest from non AE then there is no case made out by the...

  8. Addition on account of services rendered by the assessee to its AE in India - whether FTS under the provisions of Article 13(4)(c) of the India-UK DTAA? - the...

  9. 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...

  10. The Income Tax Appellate Tribunal (ITAT) held that the receipts received by the assessee, a foreign associated enterprise (AE), from HCLT for providing software,...

  11. 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...

  12. The applicant is required to pay GST on the charges paid to Indian Railways for various services received, as the applicant is the recipient of these services from...

  13. Levy of GST - international transactions - goods are supplied from a place in the non-taxable territory to another place in the non-taxable territory without such goods...

  14. Valuation - cargo handling and port services - inclusion of facility charges in the assessable value - presumption of the Revenue is that the respondent have not...

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

 

Quick Updates:Latest Updates