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1. Income accrued in India - Royalty u/s.9(1)(vi) - intra-group services fees - Coming to the Indo-Spain DTAA, it is axiomatic that the domestic law has not been linked...

2. Income taxable in India - royalty receipts - copyright - Light to broadcast “Live events” - when the agreements clearly bifurcate the consideration paid towards Live and...

3. Accrual of income in India - royalty receipt - transmission of ‘live feed’ - Income from the transmission of 'live feed' does not fall within the ambit of 'royalty'...

4. Benefit of DTAA - Article 13(6) can be pressed into service only in the case when the existence of PE of non-resident is not in dispute. In this case the assessee has...

5. Treaty benefits - ‘gains from alienation of shares' - taxability or otherwise of capital gain from sale of equity shares under Article 13(4) of India-Mauritius DTAA -...

6. 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...

7. Income deemed to accrue or arise in India - Royalty receipt - Voice Interconnect Services (IUC) - the installation and operation of sophisticated equipments are with the...

8. Classification of composite supply - works contract service - Explanation to Serial No 3(vi) of said NT, 'business' shall not include any activity or transaction...

9. The case deals with the taxability of receipts from Indian customers for providing access to online databases/journals or sale of hard copy journals. The key points are:...

10. Short term capital gain - sale of units of mutual funds - Article 13(4)/13(5) of DTAA of India-UAE - the gains arising from transfer of units of mutual funds should not...

11. Accrual of income in India - Royalty receipts - taxation of revenue from online database of text journal and books as royalty income u/Article 12 of India US DTAA - The...

12. TDS u/s 194J – the broadcast/live telecast is not a work within the definition of 2(y) of the Copyright Act and also that broadcast/ live telecast doesn’t fall within...

13. Royalty receipts for live transmission programs were not taxable as royalties under the India-Australia DTAA. The fee received for live transmission cannot be taxed as...

14. The court examined whether the receipts from services rendered by IMG to BCCI for IPL were taxable as Fees for Technical Services (FTS) under Article 13 of the India-UK...

15. Receipts on account of “Sale of Software” - chargeability to tax as income from Royalty u/s 9(1)(vi) and Article 12 of the DTAA - India-Ireland DTAA - Since treaty...