Income accrued in India - PE - India-USA DTAA - taxability of ...

Case Laws Income Tax

July 18, 2019

Income accrued in India - PE - India-USA DTAA - taxability of ‘Instructor Fee’ earned from ‘GIA India Lab’ - GIA India Lab is not acting in India on behalf of the assessee company nor having any authority to conclude contracts, it has neither concluded any contracts nor has it secured any orders for the assessee company in India, thus, cannot be regarded as agency PE - not taxable in India

View Source

← Previous Next →

Income accrued in India - PE - India-USA DTAA - taxability of ...

Case Laws Income Tax

July 18, 2019

You may also like:

Income accrued in India - Article for taxability of FTS under the India Thailand Treaty - Existence of PE in India - The assessee company has no Permanent Establishment...

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...

Income accrued in India - Shipping income earned in India - India Singapore DTAA - income is exempt in the singapore - AO has made an attempt to deny the benefit of...

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...

Income deemed to accrue or arise in India - PE in India - employees of the assessee were present in India for rendering services for a period aggregating to only 13 days...

Income deemed to accrue or arise in India - business connection in India - Permanent Establishment (PE) in India - As assessee submits that during the assessment year...

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...

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...

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...

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...

Income accrued or deemed to accrue in India - As the design services were inextricably connected with setting up of the plant and were rendered through this PE, the...

Taxability of interest on income tax refund received - PE in India or not? - whether shall be taxable as business income under Article 7 of India-France DTAA as against...

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...

Income accrued in India - Referral fees - considering that the referral activity was undertaken outside India and assessee’s Mumbai branch (PE) had no role to play in...

Income accrued in India - Taxability of the receipts of non-resident in India - fees for technical services as per the provisions of the DTAA or as per the provisions of...

Quick Updates: