Accrual of income in India - rendering leadership training to ...

Leadership Training Not Managerial Service Under DTAA; Affects India-Sweden & India-Portugal Taxation Articles.

January 7, 2021

Case Laws Income Tax AT

Accrual of income in India - rendering leadership training to employees of SAPL cannot be said as rendering managerial services so as to fall outside the ambit of fees for technical services under Article 12 (3) of the DTAA between India and Sweden read with its Protocol and the resultant Article 12 of India and Portuguese treaty. - AT

View Source

← Previous Next →

Accrual of income in India - rendering leadership training to ...

Leadership Training Not Managerial Service Under DTAA; Affects India-Sweden & India-Portugal Taxation Articles.

January 7, 2021

Case Laws Income Tax AT

You may also like:

Accrual of income in India - Fees for technical services (FTS) - taxability of receipts towards Human Resource and Leadership training provided by the assessee to its...

Taxability of income in India - receipts from services rendered to Indian entities - Fee for Technical Services (FTS) - Despite the assessee's contention that the...

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...

Accrual of income India - Service PE/ virtual service PE in India - computation of threshold date for constitution of service PE - The tribunal concluded that for AY...

Levy of IGST - reverse charge mechanism (RCM) - import of service - In the subject case other than the service provided by the applicant to MCGM, there is a very...

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...

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 - amounts received by the assessee from its Indian subsidiary towards IT and SAP charges - the services rendered under IT and...

Taxability of receipts as 'fees for included services' under the India-USA Double Taxation Avoidance Agreement (DTAA). The key points are: The Assessing Officer (AO)...

Income accrued in India - Article 15(1) of India-Austria DTAA agreement - if services are rendered outside India such income would not be taxable in India - the salary...

Corporate guarantee - fee for technical services (FTS) under article 13 of the India France DTAA and section 9(1)(vii) - services of corporate guarantee by the assessee...

The appellant provided steamer agent and cargo handling agency services, which involved segregation, internal shifting of timber logs, and sending progress reports to...

Income taxable in India - taxability of receipts from business support services as Fee - Since, the Revenue has failed to demonstrate before us that in course of...

Income taxable in India - Treating the remittance as fees for technical services - supervision installation and commissioning services - CBDT Circular No. 3/2022 is not...

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...

Quick Updates: