Tenet Tax Daily September 20 2013
No disallowance of expenditure in the absence of correct ascertainment of nature of payments to non-resident
Foreign company computing income as per a method unknown to the law of India would be qequired to correct the same in reversionary proceedings
Tenet Tax Daily September 11 2013
Interest received for delay in completion of Buy-back process of shares under open offer to be deemed as capital gain and not interest income
Tenet Tax Daily September 10 2013
Application for advance ruling rejected as question already reported in the tax return filed by the tax payer
Tenet Tax Daily September 7 2013
Prior to issue of circular 7/2009, export commission paid to NR outside India wasn’t liable to TDS
Tenet Tax Daily September 3 2013
Support Service Receipts of Thai company from Indian consultancy company is not FTS
Tenet Tax Daily September 2 2013
Concessional rate to tax the dividend isn’t available under treaty if it couldn’t be taxed in country of accrual
Tenet Tax Daily August 27 2013
Payment made for purchase of copyrighted software couldn’t be deemed as royalty
Tenet Tax Daily August 19 2013
Payments to non-residents for procuring export orders not fee for technical services or royalty
Tenet Tax Daily August 17 2013
Fees received for legal consultancy services is taxable as independent personal services as per article 15 of India-U.K. DTAA and not as fees for technical services under section 9(1)(vii) and article 7
Tenet Tax Daily August 13 2013
Receipt arising on account of commercial services rendered to American head office would be considered for determining total income of Indian branch
Tenet Tax Daily August 12 2013
Commission earned by NR agent for services rendered abroad not taxable in India in absence of PE in India
Tenet Tax Daily August 07 2013
No disallowance of Royalty paid to AE as a percentage of sales on ground that no benefit was derived by payment of Royalty
Tenet Tax Daily July 31 2013
TDS rate on payments made to resident of France excludes surcharge and education cess
Tenet Tax Daily July 30 2013
DRP to assign reasons before adjudicating claim of assessee; ITAT sets aside non-speaking order of DRP
Tenet Tax Daily July 29 2013
Payment received by foreign company from Indian franchisee for international marketing activities is not “royalty” under Article 12(4) of DTAA even if its on the basis of % of gross revenue
Tenet Tax Daily July 26 2013