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 May 2019 Year 2019 This

Disallowance u/s. 40(a)(ia) - TDS u/s 195 - no PE - Article 12 ...

Case Laws     Income Tax

May 4, 2019

Disallowance u/s. 40(a)(ia) - TDS u/s 195 - no PE - Article 12 of DTAA between India and USA - Royalties and Fees for Included Services - payments for subscription fees for accessing the server of Intelliqip for the pump data - payments is non-taxable in India and therefore no TDS is deducted which in the nature of subscription

View Source

 


 

You may also like:

  1. 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...

  2. 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...

  3. TDS u/s 195 - FTS in DTAA with USA - In view of Section 90(2) and clause 4(b) of Article 12 of the Treaty, the provisions of this Act would stand applicable only where...

  4. TDS u/s 195 - Sales commission paid to foreign company - non deduction of TDS - addition u/s 40(a)(i) - ITAT upheld the CIT(A)'s decision, noting that services rendered...

  5. TDS disallowance u/s 40(a)(i) for non-deduction on overseas payments towards patent fees, reimbursement of official fees and professional fees, treating such payments as...

  6. TDS u/s 195 - referral fee paid to a foreign concern, in USA for introducing clients - not in the nature of Managerial services,Technical services or Consultancy fees -...

  7. Disallowance u/s 40(a)(ia) - failure to deduct TDS u/s 195 - in view of Protocol between India and Spain, the restrictive meaning of ‘Fee for Technical Services’...

  8. 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...

  9. The assessee company made payments for IT service charges to a foreign entity without deducting tax at source (TDS) u/s 195. The Assessing Officer treated these expenses...

  10. TDS u/s 195 - Disallowance u/s 40(a)(ia) on account of professional consultancy fees - AO has failed to point out in what manner the professional income has arisen or...

  11. Fees for technical services (FTS) - India France DTAA - claiming the benefit of the restricted definition under India USA DTAA - Since the assessee has been found not to...

  12. TDS u/s 195 - disallowance u/s. 40(a)(i) for non deduction of TDS on payment to non-resident which is in nature of FTS(Fee for Technical Service) - beneficial provisions...

  13. 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...

  14. TDS u/s 195 - payments by resident Indian end-user to non-resident computer software manufacturers/suppliers - payment for software licenses not royalty under Article 12...

  15. TDS u/s 195 - site testing charges - Royalty - the services which can independently or on stand alone basis, be provided, coupled with the fulfillment of the other...

 

Quick Updates:Latest Updates