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Category: International Tax

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Consultant doesn’t impart any experience to client when he renders consultancy services; not to be treated as royalty

Tenet Tax Daily August 18 2014

Posted onon August 18, 2014
  • Corporate Tax
  • International Tax

Tenet News Flash – Revised India-Malta DTAA

Tenet News Flash – August 11 2014

Posted onon August 11, 2014
  • Corporate Tax
  • International Tax

Cos with huge turnover, abnormal profits or functional differences are excludible from comparables list

Tenet Tax Daily August 07 2014

Posted onon August 7, 2014
  • Corporate Tax
  • International Tax

No withholding tax liability on payment of export commission to NR before withdrawal of Circular No. 786

Tenet Tax Daily August 06 2014

Posted onon August 7, 2014
  • Corporate Tax
  • International Tax

Payment to foreign co. to conduct navigation studies at Indian port doesn’t satisfy ‘make available’ clause; no FTS

Tenet Tax Daily August 04 2014

Posted onon August 5, 2014
  • Corporate Tax
  • International Tax

AO’s referral to TPO doesn’t take away his powers of determining nature of exp. under sec. 37(1)

Tenet Tax Daily August 01 2014

Posted onon August 1, 2014
  • International Tax

Sum paid to NR for providing equipment and software to Indian clients facilitating ‘Forex deal matching’ is royalty

Tenet Tax Daily July 18 2014

Posted onon July 24, 2014
  • Corporate Tax
  • International Tax

Person whose income is subjected to withholding tax is entitled to claim its refund and not the deductor

Tenet Tax Daily June 17 2014

Posted onon June 17, 2014
  • Corporate Tax
  • International Tax

Payments for receipt of satellite signals fall within ambit of process royalty in view of FA, 2012 amendments

Tenet Tax Daily June 16 2014

Posted onon June 17, 2014
  • Individual Taxation
  • International Tax

Indian Citizen participating in golf tournament abroad deemed as NR as his stay in India was of less than 182 days

Tenet Tax Daily June 14 2014

Posted onon June 14, 2014
  • International Tax

Family pension received from UK based bank falls under residuary Article 23 of India-UK DTAA – taxable in UK only

Tenet Tax Daily June 13 2014

Posted onon June 14, 2014
  • Individual Taxation
  • International Tax

Salary earned from employment in US isn’t taxable in India if employee resides in India for less than 60 days

Tenet Tax Daily June 12 2014

Posted onon June 14, 2014
  • Corporate Tax
  • International Tax

Assessee offering marketing and support services to AEs to be held as service provider and not distributor by TPO

Tenet Tax Daily June 11 2014

Posted onon June 14, 2014
  • International Tax

TRO can’t prohibit transfer of a property unless ‘NOC’ has been obtained from AO by fraud or misrepresentation

Tenet Tax Daily June 09 2014

Posted onon June 14, 2014
  • Corporate Tax
  • International Tax

No reassessment to deny higher rate of depreciation if facts were fully disclosed during original assessment

Tenet Tax Daily June 04 2014

Posted onon June 14, 2014
  • Corporate Tax
  • International Tax

No withholding taxes from commission paid to NR agents for their services rendered outside India

Tenet Tax Daily June 02 2014

Posted onon June 2, 2014
  • Corporate Tax
  • International Tax

Sum paid to foreign co. for production of 2D and 3D animated films wasn’t fees for technical service

Tenet Tax Daily May 29 2014

Posted onon May 29, 2014
  • Individual Taxation
  • International Tax

Resident assessee can claim losses incurred from house property located abroad in return filed in India

Tenet Tax Daily May 26 2014

Posted onon May 26, 2014

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