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 October 2023 Year 2023 This

Royalty - Payment received by the taxpayer from British Airways ...

Case Laws     Income Tax

October 26, 2023

Royalty - Payment received by the taxpayer from British Airways in relation to alleged use of 'Altea system' cannot be characterized as 'royalty' either under the Act or under the Indo- Spain Treaty because Altea system was installed at the airport and was accessed only by the airlines and not by the Amadeus's agents viz. Resbird, Amadeus India and that during the year, the said system was available to British Airways for the aforesaid purpose and that too only at the airport counter and the said software was not available outside the Indian airport or to any of the agents of the taxpayer since the agents were booking the tickets only through the CRS of the taxpayer. - AT

View Source

 


 

You may also like:

  1. Income from royalty - bookings arising from India, the payment for Altea Reservation System (ARS) is made by the British Airways for the use of system for the purpose of...

  2. TP Adjustment - Adjustment in the transaction of payment of royalty - Royalty payments made by the subsidiary for using certain intangible properties and services. - The...

  3. Accrual of income in India - Royalty receipt - consideration received by the Assessee from CPI for the use of the SAP system - the ITAT is correct in holding that the...

  4. Tax authority rejected rectification application filed by taxpayer for zero-rated supply citing violation of principles of natural justice. Court examined impugned...

  5. The Appellate Tribunal addressed the issue of Tax Deducted at Source (TDS) under section 195, specifically disallowance under section 40(a)(i) for payments labeled as...

  6. TDS u/s 195 - payments by resident Indian end-user to non-resident computer software manufacturers/suppliers - payment for software licenses not royalty under Article 12...

  7. Income accrued in India - royalty receipt - As noted that the definition of royalty under the ITA, prior to amendment in 2012, as well as the DTAAs under consideration...

  8. Consideration received by the assessee on sale of software is not chargeable to tax as royalty such as equipment royalty, process royalty etc - AT

  9. Tax assessment order set aside due to defects in show cause notice, failure to consider Covid-19 impact on business operations. Taxpayer engaged in milk manufacturing...

  10. The Appellate Tribunal addressed the issue of characterizing interconnect utility charges (IUC) as 'Royalty' for TDS u/s 195 of the Income Tax Act and India-Japan DTAA....

  11. The case pertains to the valuation of imported goods and the inclusion of royalty payments for determining the transaction value. The key points are: The transaction...

  12. TDS u/s 195 - payment for time charter higher charges are Royalty u/s 9(1)(vi) - The Tribunal held that the payments made by Jaisu Shipping Co. Pvt. Ltd. for hiring...

  13. Nature of expenses - payment of royalty - acquisition of intangible asset - the appellate authorities, while deleting the disallowances made by the assessing officer,...

  14. Royalty payment to FCC Co. Ltd., Japan - revenue or capital expenditure - Either having 50% control or 100% control that will not change the colour of nature of...

  15. Recognized system of accounting - maintain its accounts according to AS-7 or AS-9 - the system of accounting followed by it for the last many years as per AS-9 -...

 

Quick Updates:Latest Updates