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 - TSIS Service Fee ...

Case Laws     Income Tax

January 31, 2023

Income deemed to accrue or arise in India - TSIS Service Fee received - The term ‘Royalty’ is not as widely defined in India France DTAA as in the India Singapore DTAA, which was taken into consideration by the coordinate bench of the Tribunal in the case of sister concern. - AO directed to delete the addition in respect of TSIS Service Fees received by the assessee. - AT

View Source

 


 

You may also like:

  1. 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...

  2. 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...

  3. 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...

  4. 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...

  5. Income deemed to accrue or arise in India - Royalty receipt - All the equipments and machines relating to the service provided by the assessee are under its control and...

  6. Income deemed to accrue or arise in India - Taxability of “cloud service fee” received by the assessee from customers in India - the payments received by the assessee...

  7. 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...

  8. 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...

  9. Income deemed to accrue or arise in India - The centralised services income, by a reasonable measure, outstrips the royalty income. Thus, rather than centralised service...

  10. The appellant qualified as a non-resident in India during the previous year 2015-16. A non-resident is taxable in India only for income received/deemed to be received or...

  11. 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...

  12. Income accrued in India - Centralized services fee received - royalty or fee for technical services The payments received were rightly held by the Tribunal, to be in the...

  13. Income accrue or arise in India - Revenue from playing of the matches in India - DTAA - Payments made to the Non- Resident Sports Associations in the present case...

  14. Income accrued in India - nature of fees for technical services - the provisions of Section 9(1)(i) are not attracted in this case as no income has accrued or arised...

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

 

Quick Updates:Latest Updates