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 October 2020 Year 2020 This

Income accrued in India - consideration received by the assessee ...

Case Laws     Income Tax

October 23, 2020

Income accrued in India - consideration received by the assessee for sale of software cannot be treated as royalty under the provision of section 9(1)(vi) of the Act as well as Article 12 of the India-Sweden DTAA and that the sale of software products by the assessee to its Indian distributors for further sale to end users is not in the nature of transfer of “copyright” and therefore not taxable in the hands of the assessee as “royalty” - AT

View Source

 


 

You may also like:

  1. Taxability of income in India - income from the sale of Software licenses subscription - India - Japan DTAA - CIT(A) held that the consideration received by the assessee...

  2. The assessee, a non-resident company incorporated in Singapore without a permanent establishment in India, received income from licensing of software to M/s. L&T Ltd....

  3. 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...

  4. Income accrued in India - Taxability as Royalty income - the income earned by the assessee from sale of software, either directly to the customers in India or through...

  5. Royalty receipts - income deemed to accrue or arise in India - assessee had sold software licenses to its associated enterprises and to other Indian customers - The ITAT...

  6. 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...

  7. Income deemed to accrue or arise in India - fee for grant of software license cannot be taxed in India. Since we have held that the subject transaction of receipt of...

  8. 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...

  9. Income accrued in India - royalty receipts - transfer of copyright in the software - India-UK DTAA - The Impugned Rulings passed by the learned AAR are set aside and it...

  10. Income deemed to accrue or arise in India - Royalty receipt - there was no transfer of copyright in the ‘off the shelf’ sale software; the consideration received thereby...

  11. Accrual of income in current AY - duty drawback and service tax refund - the income would be receivable only when the income accrues to the assessee and income would...

  12. 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...

  13. Income accrued in India - nature of fees for technical services - the provisions of Section 9(1)(i) are not attracted in this case as no income has accrued or arised...

  14. Income accrued in India - interest income on loans in the form of suppliers credit given to Indian parties - As alleged that the Indian parties from whom the assessee...

  15. 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...

 

Quick Updates:Latest Updates