Tenet Tax Daily February 13 2019
ITAT justified reassessment as Foreign Co. had failed to disclose revenue earned from its PE in India
Grouting falls under construction activity; no PE as per India-UAE DTAA if it was carried out for less than 9 months
Tenet Tax Daily February 08 2019
ITAT remanded matter to examine whether payment made for acquiring software licence was royalty
Tenet Tax Daily January 19 2019
Revisional order justified as reference to TPO was mandatory in scrutiny cases selected on TP risk parameters
Tenet Tax Daily January 18 2019
FTS should be taxable as per Article 7 in case there is no FTS clause in India-Philipines DTAA: ITAT
Tenet Tax Daily January 12 2019
Sum received by Canadian Co. for grant of licence to use technology for internal purpose only wasn’t royalty
Tenet Tax Daily January 11 2019
Gain arising from sale of shares by Spanish Co. not taxable in India by virtue of Article 14(6) of India-Spain DTAA
Tenet Tax Daily January 10 2019
No deduction towards acquisition of satellite distribution rights if films weren’t exhibited on commercial basis
Tenet Tax Daily January 08 2019
No deduction towards acquisition of satellite distribution rights if films weren’t exhibited on commercial basis
Tenet Tax Daily January 04 2019
No service PE if employee of Singaporean company had visited India for a period of only 2 days
Tenet Tax Daily December 17 2018
Exp. connected with PE couldn’t be subject to taxation laws of contracting state
Tenet Tax Daily December 11 2018
Delhi HC upheld reassessment as Samsung failed to disclose royalty income
Tenet Tax Daily November 02 2018
Sum paid for use of computer software not royalty in absence of amendment to definition of royalty in DTAA
Tenet Tax Daily October 22 2018
Legal advisory service fee received by partnership firm couldn’t be taxed under article 15 of India-UK DTAA
Tenet Tax Daily October 20 2018
Professional services provided by German & Swiss Nationals from their respected countries not taxable in India
Tenet Tax Daily October 19 2018
Indian Co. couldn’t be treated as agent if its shares held by foreign co. were sold to another foreign Co.
Tenet Tax Daily October 12 2018
No FTS if no technical knowledge was made available by AE to assessee
Tenet Tax Daily October 06 2018