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1. 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)...

2. Taxable Income in India or not - Royalty receipt - PE in India or not? - amount received towards Marketing Contribution, Priority Club receipts, Reservation...

3. 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...

4. The assessee received amounts from Indian customers for supplying software updates, patches, and on-call support services. The issue pertained to taxability of these...

5. Service tax liability assessed on various services provided/received by the appellant. Regarding director sitting fees, demand upheld along with interest, no penalty...

6. Taxability in India - amount received by the assessee from offshore supplies of plants and equipments - PE in India or not? - The Tribunal questioned the differential...

7. Income deemed to accrue or arise in India - treatment of "Commission income" and receipts from "Subscription fee" - Assessee in publishing business receiving...

8. Levy of service tax - The appellant is not liable to pay service tax on Export Pass fee, Import Pass fee, Permit fee, Excise Staff Salary and overtime allowances/charges...

9. 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...

10. TDS u/s 195 - Taxability of income in India - PE in India - taxation of offshore supplies - Taxation of Fee for Technical Services (FTS) in the absence of FTS article...

11. Levy of tax on the royalties or fees for technical services - rate of tax under the DTAA - 12% or 10% - the substitution has the effect of deleting the old rule and...

12. Fees for technical service was liable to tax in India under section 44BB of the Act only if the appellant had Permanent Establishment ("PE") in India in the relevant...

13. Levy of service tax on ATM interchange fees received by State Bank of Hyderabad from SBI for deploying its ATMs in the shared network, and on notional consideration for...

14. The assessee's income received from Indian customers as Fee for Technical Services (FTS)/Fee for Included Services (FIS) u/s 9(1)(vii) of the Act and Article 12(4) of...

15. Income deemed to accrue or arise in India - offshore supply of design and engineering inextricably linked with manufacturing and supply of equipment, not taxable as Fees...