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 January 2022 Year 2022 This

Income accrues or arises in India - services to MTR foods ...

Case Laws     Income Tax

January 27, 2022

Income accrues or arises in India - services to MTR foods Private Limited who is located outside India - Secondment charges paid in respect of the professional services rendered - classification as FTS - Nothing is made available by non resident Assessee to MTR Foods in India. Accordingly the services rendered by the non resident assessee to MTR Foods are not taxable as per India Singapore DTAA. Since the non resident assessee do not have a permanent establishment in India, the income so arising cannot be taxed under Article 7 as 'business profits' either. - AT

View Source

 


 

You may also like:

  1. Income Accrue or arise in India - FTS - the ultimate delivery of the software was outside India - Since there is no dispute that the services were rendered outside India...

  2. 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...

  3. Income deemed to accrue or arise in India - non-resident corporate entity - Taxability of royalty income received by the assessee on subscribers units from original...

  4. 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...

  5. TDS u/s 195 - disallowance u/s 40(a)(i) - commission paid to non-resident outside India for the services rendered outside India will not fall in the category of the...

  6. Place of supply - supplier of service and recipient of service are located in India - immovable property located outside India - The applicant who is the supplier of...

  7. 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...

  8. The commission has been paid to non-resident outside India for services rendered outside India - where the non-resident agent operates outside India, no part of his...

  9. 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...

  10. Levy of service tax - applicability of Reverse Charge Mechanism - Business Auxiliary Service - he services have been provided by the foreign agents to the foreign site...

  11. 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...

  12. TDS u/s 195 - sales commission expenses paid to agents outside India - The commission income earned by foreign agents for services rendered outside India does not accrue...

  13. Profit in lieu of salary for services rendered outside India - said income did not accrue or arise in India in terms of Section 6 and Section 9(1) (ii) - HC

  14. BAS - export of services or not - the sale of the products and services manufactured or provided by the Foreign Company have been made by the assessee to the Indian...

  15. Where the employee discharges his duties outside India and his stay is beyond the prescribed limit to term him resident, the income earned earned upon such discharge of...

 

Quick Updates:Latest Updates