![Business Profits of Non-Residents without PE are not Taxable under DTAA, TDS not sustainable: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/05/Business-profits-Non-resident-PE-DTAA-TDS-ITAT-taxscan.jpg "Business Profits of Non-Residents without PE are not Taxable under DTAA, TDS not sustainable: ITAT [Read Order]")
Business Profits of Non-Residents without PE are not Taxable under DTAA, TDS not sustainable: ITAT [Read Order]
The Income Tax Appellate Tribunal (ITAT), New Delhi before Shri N K Billaiya, AM and Ms Astha Chandra, JM held that Payments made on the business...
![Receipts in nature of Royalties not Taxable as per India-USA DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/05/Royalties-Taxable-India-USA-DTAA-ITAT-Taxscan.jpg "Receipts in nature of Royalties not Taxable as per India-USA DTAA: ITAT [Read Order]")
![Set Back to Infosys; Payment of Sub-Contracting Charges to Subsidiary is Liable to TDS: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/04/Infosys-Payment-Sub-Contracting-Charges-Subsidiary-TDS-ITAT-Taxscan.jpg "Set Back to Infosys; Payment of Sub-Contracting Charges to Subsidiary is Liable to TDS: ITAT [Read Order]")
![Payment for Transponder Services does not amount to Royalty: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/04/Payment-Transponder-Services-Royalty-ITAT-Taxscan.jpeg "Payment for Transponder Services does not amount to Royalty: ITAT [Read Order]")
![Collection Charges received by Lufthansa German Airlines from AAI can’t be treated as Income from Operation of Aircraft as per DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/03/Lufthansa-German-Airlines-AAI-Income-Aircraft-DTAA-ITAT-TAXSCAN.jpeg "Collection Charges received by Lufthansa German Airlines from AAI can’t be treated as Income from Operation of Aircraft as per DTAA: ITAT [Read Order]")
![Subscriber Fee not Taxable as Royalty as per India-Singapore DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/03/Subscriber-Fee-Taxable-Royalty-India-Singapore-DTAA-ITAT-fee-India-Singapore-DTAA-Taxscan.jpg "Subscriber Fee not Taxable as Royalty as per India-Singapore DTAA: ITAT [Read Order]")
Income from Online Database of Text Journals and Books not 'Royalty' as per Indo-US DTAA: ITAT [Read Order]
The Delhi bench has held that the income from an online database of text journals and books would not constitute royalty income under the provisions of the Double Taxation Avoidance Agreement (DTAA)...
![Income from Online Database of Text Journals and Books not Royalty as per Indo-US DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/03/ITAT-Delhi-Income-Online-Database-Text-Journals-Books-Royalty-Indo-US-DTAA-ITAT-Taxscan.jpeg "Income from Online Database of Text Journals and Books not Royalty as per Indo-US DTAA: ITAT [Read Order]")
Foreign Company not Taxable in India for Interest on Income Tax Refund not Connected to PE Under DTAA: ITAT [Read Order]
The Dehradun Bench of ITAT has held that interest on income tax refund received by a foreign enterprise is not effectively connected to its Permanent Establishment in India and therefore it cannot be...
![Foreign Company not Taxable in India for Interest on Income Tax Refund not Connected to PE Under DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/03/Foreign-Company-Interest-On-Income-Tax-Refund-DTAA-ITAT-TAXSCAN.jpg "Foreign Company not Taxable in India for Interest on Income Tax Refund not Connected to PE Under DTAA: ITAT [Read Order]")
Inspection & Examination of Goods before Shipment cannot be treated as ‘Technical & Managerial Services’: ITAT deletes Addition [Read Order]
The Income Tax Appellate Tribunal (ITAT), Delhi bench has held that the activity of inspection and examination of goods before shipment cannot be treated as technical and managerial services under...
![Inspection & Examination of Goods before Shipment cannot be treated as ‘Technical & Managerial Services’: ITAT deletes Addition [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/02/Inspection-ITAT-ITAT-Delhi-Technical-Managerial-Services-Examination-of-Goods-Taxscan.jpg "Inspection & Examination of Goods before Shipment cannot be treated as ‘Technical & Managerial Services’: ITAT deletes Addition [Read Order]")
No Retrospective Effect of CBDT Circular, requiring separate notification by Govt for Importing the benefit of MFN into DTAA: ITAT [Read Order]
The Pune Bench of Income Tax Appellate Tribunal (ITAT) has held that No Retrospective effect of Central Board of Direct Taxes (CBDT) Circular, requiring separate notification by Government for...
![No Retrospective Effect of CBDT Circular, requiring separate notification by Govt for Importing the benefit of MFN into DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/02/Retrospective-Effect-CBDT-Government-importing-MFN-DTAA-ITAT-taxscan.jpg "No Retrospective Effect of CBDT Circular, requiring separate notification by Govt for Importing the benefit of MFN into DTAA: ITAT [Read Order]")
CBDT issues Clarification on MFN clause in Protocol to India's DTAAs with certain Countries [Read Circular]
The Central Board of Direct Taxes (CBDT) has issued the clarification regarding MFN clauses in Protocol to India's DTAAs with certain countries. The Protocol to India's Double Taxation Avoidance...
![CBDT issues Clarification on MFN clause in Protocol to Indias DTAAs with certain Countries [Read Circular]](https://www.taxscan.in/wp-content/uploads/2022/02/CBDT-DTAA-MFN-Taxscan.jpg "CBDT issues Clarification on MFN clause in Protocol to Indias DTAAs with certain Countries [Read Circular]")
Delhi HC directs Income Tax Dept. to reconsider issue of issuance of Certificate with ‘NIL’ deduction of Income Tax after granting opportunity of hearing [Read Order]
The Delhi High Court directed the Income Tax Department to reconsider the issue of issuance of the certificate with ‘NIL’ deduction of income tax after granting the opportunity of hearing. The...
![Delhi HC directs Income Tax Dept. to reconsider issue of issuance of Certificate with ‘NIL’ deduction of Income Tax after granting opportunity of hearing [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/01/Delhi-High-Court.jpg "Delhi HC directs Income Tax Dept. to reconsider issue of issuance of Certificate with ‘NIL’ deduction of Income Tax after granting opportunity of hearing [Read Order]")