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 2023 Year 2023 This

Income deemed to accrue or arise in India - “Live” Feed or ...


India-Singapore Tax Treaty: 25% of Licensee Fee from Set Satellite Deemed for Non-Live Content in "Live" Feeds.

January 5, 2023

Case Laws     Income Tax     AT

Income deemed to accrue or arise in India - “Live” Feed or “modified” Feed - Allocation/apportionment of the Licensee Fee income - receipts from Set Setellite Singapore Pte. Ltd. (SET) - benefit of India Singapore Tax Treaty - 25% of Licensee Fee is fair estimation of the Licensee Fee attributable to the Non-Live Exhibitions and recorded content in “Live” Feed. There is no material placed on record by both the sides to arrive at the more precise or better estimation/apportionment. - AT

View Source

 


 

You may also like:

  1. Assessee employed by Indian entity but sent on long-term international assignment to Singapore. Salary received in India for administrative reasons, but employment...

  2. The assessee failed to deduct tax on professional fees paid to various non-residents. The Assessing Officer (AO) held that the fees were liable to tax in India under the...

  3. The ITAT ruled in favor of the taxpayer, determining that fabrication charges received could not be treated as "fees for technical services" under Article 12(4)(a) of...

  4. The Appellate Tribunal considered the taxability of freight income u/s 44B for a foreign company incorporated in Singapore operating ships globally, including in India....

  5. Income deemed to accrue or arise in India - Fee for Technical Services (FTS)/ Fee for Included Services (FIS) - the services provided by the assessee under the marketing...

  6. 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...

  7. Claim of foreign tax credit (FTC) u/s 90 or u/s 91 - Applicability or Rule 128 with retrospective effect - In view of Singapore Taxation Laws the income in question is...

  8. Income accrued in India - Shipping income earned in India - India Singapore DTAA - income is exempt in the singapore - AO has made an attempt to deny the benefit of...

  9. Entitlement to benefits of treaty exemption - India-Singapore DTAA - Application of Section 172 - Taxation of shipping companies - The tribunal concluded that the...

  10. 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...

  11. Income deemed to accrue or arise in India - existence of Agency PE/ Fixed Place PE - Indian-Singapore Tax Treaty - applying the legal principle to the facts emerging on...

  12. Taxability of income - Characterization of receipts - software sub-licence fee - the income in dispute, since can be classified under other Articles of the tax treaty,...

  13. Rate of TDS - Non-availability of PAN - Benefit of treaty - in case of payments made to non-residents, the assessee was entitled to deduct taxes at source at the rates...

  14. Income deemed to accrue or arise in India - taxation of entire revenue received by the Appellant from provision of legal services on Indian engagements - Fees for...

  15. Denial of tax treaty benefit due to lack of commercial substance in Singapore - Benefit of DTAA - In any event, the ld. AO in all fairness ought to have accepted the...

 

Quick Updates:Latest Updates