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1. Income deemed to accrue or arise in India - interest income - In these years, the interest income has accrued on the deposits kept by the assessees in HSBC bank, Geneva...

2. Income accrued in India - permanent establishment (PE) - Withholding of tax in India - vessel engaged in seismic survey at high sea - The sum paid by the applicant to...

3. TDS u/s.196C r.w.s. 115AC on the interest payable on FCCBs - since income in question is squarely falling under the exclusion clause of income deemed to accrue or arise...

4. 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...

5. Income accrues or arises or deemed to accrue or arise in India - Unexplained foreign income - residential status of the assessee - The Tribunal upheld the CIT(A)'s...

6. Income deemed to accrue or arise in India - The centralised services income, by a reasonable measure, outstrips the royalty income. Thus, rather than centralised service...

7. Duty of AO to Guide the Assessee - Considering the specific facts on record that the assessee is non resident the amount which the ld. AO has taxed is earned and sourced...

8. TDS u/s 195 - As the assessee rendered "International services" outside India which required the payment in question. If this is the position, which has not even been...

9. Tax withholding liability - liability to deduct tax at source u/s 196C r.w.s. 115AC on the interest payable on FCCBs - since income in question is squarely falling under...

10. The issue pertains to whether the amounts received as sales commission by a non-resident assessee are in the nature of fees for included services, and whether such...

11. Income Accrue or arise in India - FTS - the ultimate delivery of the software was outside India - Since there is no dispute that the services were rendered outside India...

12. Income accrue or arise in India - Revenue from playing of the matches in India - DTAA - Payments made to the Non- Resident Sports Associations in the present case...

13. The summary highlights the key difference between the scope of total income under the Income Tax Act and the Black Money (Undisclosed Foreign Income and Assets) and...

14. Accrual of income - Addition on account of amount kept in Escrow Account - slump sale - The word “accruing” and arising are used to contradistinguish the word “receive”....

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