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1. Non deduction of TDS on payment to non-resident - disallowance u/s 40(a)(i) - a similar payment to a resident does not result in disallowance in the event of non...

2. TDS u/s 195 - Since Section 40(a)(i) as it stood in AY 2006-07 continued to discriminate in the above manner and was inconsistent with Article 24(3) of the Indo Japan...

3. DTAA with Slovenia - Exchange of information - Article 26 as amended w.e.f. 1.3.2017

4. Taxability of income in India - Interest income on income tax refund - As referring to relevant Article 11 of Indo-US DTAA with regard to interest it can be concluded...

5. DTAA with New Zealand - Exchange of information - Article 26 as amended.

6. TDS u/s 195 - Addition u/s 40(a)(i) - remittances without deducting tax at source [TAS] - disallowances qua payments made by assessee concerning purchases from its seven...

7. Income accrued in India - tratement of Income from cloud hosting services as royalty - income from cloud hosting services has erroneously held as royalty within the...

8. 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...

9. TDS u/s 195 - DTAA with Uganda - professional services - the services received by the assessee from these three persons is covered by article 14 and therefore, the same...

10. DTAA with Slovenia - ASSISTANCE IN THE COLLECTION OF TAXES - New Article 27 w.e.f. 1.3.2017

11. Withholding tax credit deducted by US based subsidiary of the assessee company in USA on payment of interest loan - Indo-US DTAA - If the TDS certificate is produced by...

12. Disallowance u/s 40(a)(ia) - failure to deduct TDS u/s 195 - in view of Protocol between India and Spain, the restrictive meaning of ‘Fee for Technical Services’...

13. This case deals with the accrual of income in India from exploration activities and the determination of whether the assessee has a Permanent Establishment (PE) in India...

14. 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)...

15. 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...