Fees for Included Services in terms of Article 12 of the India ...

Case Laws Income Tax

July 26, 2012

Fees for Included Services in terms of Article 12 of the India US treaty - the payment received by the assessee from Lucent is taxable in India under Article 12 as fees for included services. - AT

View Source

← Previous Next →

Fees for Included Services in terms of Article 12 of the India ...

Case Laws Income Tax

July 26, 2012

You may also like:

Income accrued in India - Fee for Technical/Included Services - whether the amount received by the assessee for various services, commonly known as centralized services,...

Income deemed to accrue or arise in India - Fee for Technical Services (FTS)/ Fee for Included Services (FIS) - the services provided by the assessee under the marketing...

Income taxable in India - payments received from its India customers on account of Centralized Services - Fee for Technical Services - Fee for included services - The...

Income accrued or deemend to accrue in India - Fees for technical services' under Article 12(5)(a) of the India-Netherlands tax treaty - as providing of access to CRS,...

TDS u/s 195 - DTAA with Uganda - professional services - the services received by the assessee from these three persons is covered by article 14 and therefore, the same...

Income accrued in India - TDS u/s 195 - fees for included services (FTS) - USA DTAA - the PGCIL would not apply technology on its own. It would continue to depend on the...

Taxability of receipts as 'fees for included services' under the India-USA Double Taxation Avoidance Agreement (DTAA). The key points are: The Assessing Officer (AO)...

Accrual of income in India - PE in India or not? - use or right to use brand name/trade mark - the receipts cannot be treated as royalty under Article 12(3)(a) of the...

The assessee's income received from Indian customers as Fee for Technical Services (FTS)/Fee for Included Services (FIS) u/s 9(1)(vii) of the Act and Article 12(4) of...

Income taxable in India - Management Support Charges - the fee received by the assessee under the Centralized Services Agreement cannot be treated as FIS either under...

The key points in the legal document are: Software licensing amounts do not qualify as Fees for Included Services under Article 12(4)(b) of the India-US DTAA, as the...

The income deemed to accrue or arise in India, including reimbursement received for SAP Software and Microsoft License fees, was held to be taxable as royalty receipts...

Income accrued in India - treatment to management fee and IC Labour Charges as fee for technical services/fee for included services - FTS / FIS - These services have not...

Tax credit under article 23(2) of India Japan Double Taxation Avoidance Agreement ['Indo Japanese tax treaty'] - on the peculiarities of Indo Japanese tax treaty...

The assessee received amounts from Indian customers for supplying software updates, patches, and on-call support services. The issue pertained to taxability of these...

Quick Updates: