Income deemed to accrue or arise in India - fee for technical ...

Case Laws Income Tax

May 26, 2023

Income deemed to accrue or arise in India - fee for technical services / FTS - If it is of recurring annual fees, there is no question that assessee was making available any technology or knowhow of the Indian customers on year to year basis as has been interpreted by the ld. AO. Assessee is having the technical expertise in the software sub-licensed by it. If there is any bug or problem faced by the customers while using the software, assessee provides trouble shooting to fix those bugs and helps them for maintaining and support of the software used by the clients. This does not mean that assessee had made available any technology in software. - AT

View Source

← Previous Next →

Income deemed to accrue or arise in India - fee for technical ...

Case Laws Income Tax

May 26, 2023

You may also like:

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...

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...

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

Income accrued in India - treatment to management fee and IC Labour Charges as fee for technical services/fee for included services - FTS / FIS - These services have not...

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...

Income deemed to accrue or arise in India - Fees for Technical Services (FTS)/Fees for Included Services (FIS) - Assessee is not the ultimate beneficiary of the sum in...

Taxability of foreign income in India - use of Virtual Voice Network (VVN) - Income deemed to accrue or arise in India - PE in India - The grounds of the Revenue were...

Income accrued or deemend to accrue in India - Fees for technical services' under Article 12(5)(a) of the India-Netherlands tax treaty - as providing of access to CRS,...

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...

Income deemed to accrue or arise in India - receipts of subscription fees - The ITAT had found that it did not involve the transfer of copyright or the provision of...

Income deemed to accrue or arise in India - FTS/FIS - receipts pertaining to supply of software (including AMC services) - The tribunal confirmed that software licensing...

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...

Income deemed to accrue or arise in India - PE in India - employees of the assessee were present in India for rendering services for a period aggregating to only 13 days...

Income deemed to accrue or arise in India - amounts received by the assessee from its Indian subsidiary towards IT and SAP charges - the services rendered under IT and...

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...

Quick Updates: