Tenet Tax Daily September 14 2018
Residency certificate was sufficient evidence for accepting residential status as per India-Mauritius Tax treaty
Liaison Office couldn’t be treated as PE of foreign Co. if it didn’t finalize & transact a business deal on its own
Tenet Tax Daily September 11 2018
Sum paid as ‘affiliation fee’ not connected with transfer of technology couldn’t be treated as royalty
Tenet Tax Daily September 03 2018
No FTS if no technical knowledge was made available to enable recipients to use services independently
Tenet Tax Daily August 23 2018
Inland Haulage Charge is income from shipping operations; exempt as per Article 9 of India-France DTAA
Tenet Tax Daily July 23 2018
Support and service fees not taxable as FTS as it didn’t satisfy make available clause
Tenet Tax Daily July 19 2018
Sale consideration of copyrighted software couldn’t be taxed as royalty: Mumbai ITAT
Tenet Tax Daily July 03 2018
Payment to contractor engaged in collection of data which doesn’t mandate technical skills requires sec. 194C TDS
Tenet Tax Daily June 29 2018
Sum paid to Foreign Co. towards supervision & installation of pipes and fittings couldn’t be held as FTS
Tenet Tax Daily June 28 2018
Commission paid to foreign agents on export of goods not taxable in absence of any business connection in India
Tenet Tax Daily June 13 2018
Delegation of responsibility by Head Office to Project Office to be considered as international transaction
Tenet Tax Daily May 23 2018
HC dismissed ‘Vodafone’ petition as hearing opportunity was provided during cancellation of lower TDS certificate
Tenet Tax Daily May 22 2018
ITAT remanded matter as TPO had characterized distribution agreement as a service agreement
Tenet Tax Daily May 14 2018
Vessels engaged in seismic surveys by NR on High seas relating to contract with ONGC constituted its fixed place PE
Tenet Tax Daily May 08 2018
HC condones delay in filing ITR of NRI as there was delay due to severe financial crisis in USA
Tenet Tax Daily May 05 2018
Domain registration fee received by ‘GoDaddy’ is taxable as royalty in India: Delhi ITAT
Tenet Tax Daily May 03 2018
Fees paid by ‘Deloitte’ to Foreign Co. for gaining knowledge about foreign tax laws not taxable in India
Tenet Tax Daily May 02 2018
No withholding taxes from freight paid to foreign shipping co. which was assessed under sec. 172
Tenet Tax Daily April 26 2018