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 July 2020 Year 2020 This

Existence of PE - addition on account of salary reimbursement ...

Case Laws     Income Tax

July 25, 2020

Existence of PE - addition on account of salary reimbursement cost treated as fee for technical services - the burden of proving that the foreign assessee has a PE in India and consequently it has to be taxed on the business generated by such PE is initially on the Revenue. - There will be no income attributable to the PE. - AT

View Source

 


 

You may also like:

  1. Fees for Technical Services [FTS] - Receipt of Cost-to-cost reimbursements on account of secondment of employees - seconded personnel are employees of EY India firms -...

  2. Taxability of employee cost reimbursements as Fee for Technical Services (FTS) under the India-Japan tax treaty. The assessee, a Japanese company, seconded employees...

  3. 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...

  4. Fees for Technical Services - Reimbursement of salary and other related costs - the salaries of such seconded employees were deposited in their overseas bank accounts,...

  5. The assessee, a foreign company, earned network transportation fees from its Indian associated enterprise (AE), Damco India Private Limited (DIPL). The Assessing Officer...

  6. Reimbursement of salary cost treated as fees for technical services – Royalty u/s 9(1)(vii) – Indo-US DTAA - If there is a PE, then Royalty or FIS cannot be taxed under...

  7. TDS u/s 192 - secondment agreement - Addition of payment/reimbursement of amount on account of salary, relocation and other related costs of expatriate employees - TDS...

  8. The Delhi High Court addressed issues related to reimbursement of software costs, reimbursement of expatriate salaries, and lease registration charges. The court held...

  9. The taxpayer, an IT/support services provider, received reimbursements from its associated enterprises (AEs) for the cost of providing such services. The tax authorities...

  10. Addition on account of licence fee paid to DOT - if any expenditure on account of licence fee was payable up to 31.07.1999, it should be treated as capital expenditure...

  11. Scope of NCLT Rules - fees mentioned in Rule 112 read with the definition clause 2(12) does not mention either CIRP costs or the fees to be paid to the IRP or RP. The...

  12. Transfer pricing adjustment on international transaction involving payment of guarantee fees to associated enterprise was held unjustified. Assessee demonstrated...

  13. Reimbursement of salary costs of seconded personnel - whether is in the nature of ‘fees for technical services’ u/s 9(1)(vii) - TDS u/s 195 - all the payment made by...

  14. Taxability of foreign income in India - use of Virtual Voice Network (VVN) - Income deemed to accrue or arise in India - PE in India - The grounds of the Revenue were...

  15. Addition made u/s 153A on account of undisclosed foreign bank account and interest income thereon - assessee confronted with client profiles from HSBC Bank showing...

 

Quick Updates:Latest Updates