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 March 2019 Year 2019 This

Accrual of income in India - Provision of the software solutions ...


Income Accrual from Software Solutions in India: No Additional Taxation Required Due to Arm's Length Principle Compliance.

March 12, 2019

Case Laws     Income Tax     AT

Accrual of income in India - Provision of the software solutions for onward distribution to third party customers in India - since the appropriate ‘arm’s length principle’ has been satisfied in the present case, nothing more would be left to be taxable in India by attributing any further income to the PE of the assessee in India

View Source

 


 

You may also like:

  1. Accrual of income in India - taxability of the “software” supplied to Indian affiliates - The Tribunal's decision effectively overturns the AO's and DRP's stance,...

  2. Accrual of income in India - royalty income - supply of software - absence of PE of the assessee in India - The Tribunal held that, the payments received by the assessee...

  3. 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...

  4. The assessee, a non-resident company incorporated in Singapore without a permanent establishment in India, received income from licensing of software to M/s. L&T Ltd....

  5. Income accrued in India - Taxability as Royalty income - the income earned by the assessee from sale of software, either directly to the customers in India or through...

  6. TDS u/s 195 - Taxability of income in India - PE in India - taxation of offshore supplies - Taxation of Fee for Technical Services (FTS) in the absence of FTS article...

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

  9. 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...

  10. Income deemed to accrue or arise in India - FTS/FIS - receipts pertaining to supply of software (including AMC services) - The tribunal confirmed that software licensing...

  11. 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...

  12. Applicability of Article 7 of the Double Taxation Avoidance Agreement (DTAA) between India and the United Arab Emirates regarding the taxation of profits attributed to a...

  13. Interpretation of Section 44BB and 44DA - bifurcation between the supply of software as well as ancillary services such as maintenance and installation - It is question...

  14. Rectification u/s 154 - taxation of salary income earned in USA - The appeal before the Appellate Tribunal involved various issues related to the taxation of income...

  15. Taxability of income in India - Income attributable to India - income of advertisement and subscription revenue - Permanent Establishment (PE) - business connection -...

 

Quick Updates:Latest Updates