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No PE in India: Uptodate Not Taxable under “Royalty” for Allowing Access to Online Database of Journals and Books, rules ITAT [Read Order]

Gayathri C.H

The Income Tax Appellate Tribunal, Delhi Bench, has recently, in an appeal filed before it, held thatM/s. Uptodate is not taxable under “royalty” for...

Salary received in India for Services rendered in USA during Short Term Assignment Not Taxable in...

Distribution Revenue received by CNN Not “Royalty”: ITAT [Read Order]

ITAT orders Re-examination on Applicability of TDS u/s 195 of Income Tax Act on Payment made to...

Initiation of Re-Assessment Against Vodafone for Non-payment of TDS on Sale of Bharti Airtel's...

No TDS on Payment of Fee to Singapore Entity: ITAT Grants Relief to Standard Chartered [Read Order]

The Income Tax Appellate Tribunal ( ITAT ), Chennai bench has held that TDS is not payable on the payment of training fee to the Singapore entity as per the relevant double taxation avoidance...

Guarantee Commission is not Taxable in India under India Germany DTAA: ITAT directs AO to delete Transfer Pricing Adjustment [Read Order]

The Income Tax Appellate Tribunal (ITAT), Mumbai Bench directed Assessing Officer (AO) to delete transfer pricing adjustment and held that Guarantee commission is not taxable in India as per India...

Amount in Nature of Debt Claim, till possession was actually handed over is Taxable under India UK DTAA: ITAT [Read Order]

The Chandigarh Bench of the Income Tax Appellate Tribunal (ITAT), ruled that amount in nature of debt claim till possession of was actually handed over is taxable under India-UK Double Taxation...

Benefit of India UK DTAA allowable to LLP on portion of Income from Indian Engagements: ITAT [Read Order]

The Income Tax Appellate Tribunal (ITAT), New Delhi Bench held that Benefit of India UK Double Taxation Avoidance Agreement (DTAA) allowable to Limited Lability Partnership (LLP) on portion of Income...

Payment received under Master Franchise Agreement cannot treat as Royalty: ITAT deletes Addition [Read Order]

The Delhi bench of Income Tax Appellate Tribunal (ITAT) has deleted the Addition and held that payment received under Master Franchise Agreement could not be treated as Royalty. The instant case,...

More than 15% of revenue generated from India can’t be attributed to PE in India when risk assumed in earlier years had not changed: ITAT [Read Order]

The Delhi Bench of Income Tax Appellate Tribunal (ITAT) has held that more than 15% of the revenues generated from India can’t be attributed to the PE in India when the risk assumed in earlier years...

No Income attributed to DAPE of Adobe-Ireland in India, When Transaction between Indian AE and Foreign party found at ALP: ITAT [Read Order]

No income attributed to DAPE of Adobe-Ireland in India, when transaction between Indian AE and foreign party found at arm’s length price, so was held by the Income Tax Appellate Tribunal (ITAT), New...

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