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 2024 Year 2024 This

Income Accrue or arise in India - FTS - the ultimate delivery of ...

Case Laws     Income Tax

January 8, 2024

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 to the customers outside India, no part of the income accrues or arises or deemed to accrue or arise in India and accordingly the provisions of section 5(2)(b) of the Act are not applicable in the instant case. - AT

View Source

 


 

You may also like:

  1. 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...

  2. 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...

  3. 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...

  4. 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...

  5. 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...

  6. 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...

  7. 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...

  8. 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...

  9. 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...

  10. Duty of AO to Guide the Assessee - Considering the specific facts on record that the assessee is non resident the amount which the ld. AO has taxed is earned and sourced...

  11. 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...

  12. 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...

  13. Income deemed to accrue or arise in India - fee for grant of software license cannot be taxed in India. Since we have held that the subject transaction of receipt of...

  14. Income accrued in India - Article for taxability of FTS under the India Thailand Treaty - Existence of PE in India - The assessee company has no Permanent Establishment...

  15. 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...

 

Quick Updates:Latest Updates