Tenet Tax Daily May 23 2014
ITAT teaches basics to AO: Income earned by ‘RNOR’ from services rendered abroad wasn’t taxable in India
No remand order as CIT(A) had analyzed all clauses of India-UK DTAA to hold that sums couldn’t be taxed as royalty
Tenet Tax Daily May 22 2014
Sum received by Warner Bros. for distribution of films in India isn’t ‘royalty’; ITAT follows previous decision
Tenet Tax Daily May 14 2014
Income of NR agent for arranging NR Artists in India not taxable in status of ‘Entertainer’ under India-UK DTAA
Tenet Tax Daily May 05 2014
Sum paid to acquire rights of telecasting from outside India, in absence of its link with PE in India, wasn’t royalty
Tenet Tax Daily May 03 2014
Incentives to subscribers for generating additional revenue is a ‘selling exp.’ to be excluded from AMP expenses
Tenet Tax Daily April 30 2014
Payment for software licensed to foreign HO and used by Indian branch with non-exclusive rights isn’t ‘royalty’
Tenet Tax Daily April 29 2014
HC lays criteria to identify AOP;relies on ratio of ‘Ishikawajima-Harima’ for taxability of offshore supplies
Tenet Tax Daily April 25 2014
Presumptive taxation under sec. 44DA couldn’t invoked if services were squarely covered by sec. 44BB
Tenet Tax Daily April 24 2014
When applying CUP method international transaction can be compared with actual transaction and not with mere ‘quotation’
Tenet Tax Daily April 21 2014
SECTION 90 OF THE INCOME-TAX ACT, 1961 – DOUBLE TAXATION AGREEMENT – AGREEMENT FOR AVOIDANCE OF DOUBLE TAXATION AND PREVENTION OF FISCAL EVASION WITH FOREIGN COUNTRIES – SRI LANKA
Tenet Tax Daily April 12 2014
Payment for transponder service is ‘royalty’; ITAT refers Explanation 6 to sec. 9(1)(vi) to interpret ‘process’
Tenet Tax Daily April 10 2014
ITAT explains interplay between Article 7 and Article 13 of India-UK DTAA
Tenet Tax Daily April 09 2014
ITAT explains interplay between Article 7 and Article 13 of India-UK DTAA
Tenet Tax Daily April 09 2014
No withholding from sum paid to NR agent who was assisting to win a contract to be carried outside India
Tenet Tax Daily April 07 2014
Cross-charge of salaries not involving any profit element is not income to the foreign company and assessee was not required to deduct TDS
Tenet Tax Daily April 01 2014