![Receipt from Support Services cannot be Treated as FIS under Article 12(4)(b) of India -USA DTAA: ITAT Deletes Income Tax Addition [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/10/Receipt-from-Support-Services-Treated-as-FIS-under-India-USA-DTAA-ITAT-Income-Tax-TAXSCAN.jpg "Receipt from Support Services cannot be Treated as FIS under Article 12(4)(b) of India -USA DTAA: ITAT Deletes Income Tax Addition [Read Order]")
Receipt from Support Services cannot be Treated as FIS under Article 12(4)(b) of India -USA DTAA: ITAT Deletes Income Tax Addition [Read Order]
The Delhi Bench of Income Tax Appellate Tribunal (ITAT) held that services rendered are not in relation to any manufacturing activity, therefore the...
![DTAAs not to be Enforced without Central Govt. Notification u/s 90 of Income Tax Act: Supreme Court in MFN Case [Read Judgement]](https://www.taxscan.in/wp-content/uploads/2023/10/DTAAs-Enforced-without-Central-Govt-Notification-Income-Tax-Act-Supreme-Court-in-MFN-Case-TAXSCAN.jpg "DTAAs not to be Enforced without Central Govt. Notification u/s 90 of Income Tax Act: Supreme Court in MFN Case [Read Judgement]")
![Consultancy Services cannot be Treated as FIS Merely because Service Provider has used Substantial Technical Skill as per India-USA DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/Consultancy-Services-Treated-FIS-Merely-Service-Provider-Substantial-Technical-Skill-India-USA-DTAA-ITAT-taxscan.jpg "Consultancy Services cannot be Treated as FIS Merely because Service Provider has used Substantial Technical Skill as per India-USA DTAA: ITAT [Read Order]")
Salary Accrued for Work Performed in Foreign Jurisdiction is not Taxable but Salary Received for Work Performed in India would be Taxable: ITAT Allows Benefits under India-China DTAA [Read Order]
The Chennai Bench of Income Tax Appellate Tribunal (ITAT) held that salary income as accrued to the assessee for work performed in a foreign jurisdiction would not be taxable in India whereas the...
![Salary Accrued for Work Performed in Foreign Jurisdiction is not Taxable but Salary Received for Work Performed in India would be Taxable: ITAT Allows Benefits under India-China DTAA [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/Salary-Accrued-for-Work-Performed-Salary-Accrued-Foreign-Jurisdiction-Salary-Received-for-Work-Performed-in-India-ITAT-Allows-Benefits-under-India-China-DTAA-Salary-Received-India-China-DTAA-taxscan.jpg "Salary Accrued for Work Performed in Foreign Jurisdiction is not Taxable but Salary Received for Work Performed in India would be Taxable: ITAT Allows Benefits under India-China DTAA [Read Order]")
Capital Gain Derived by Sale of Equity Shares not Taxable in terms of Article 13(4) of India-Mauritius DTAA: ITAT [Read Order]
The Delhi Bench of Income Tax Appellate Tribunal (ITAT) has held that the capital gain derived by the sale of equity shares is not taxable in terms of Article 13(4) of the India Mauritius Double...
![Capital Gain Derived by Sale of Equity Shares not Taxable in terms of Article 13(4) of India-Mauritius DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/ITAT-capital-Gain-Capital-Gain-Derived-by-Sale-of-Equity-Equity-India-Mauritius-DTAA-taxscan.jpg "Capital Gain Derived by Sale of Equity Shares not Taxable in terms of Article 13(4) of India-Mauritius DTAA: ITAT [Read Order]")
Income from sub licensing software for healthcare business in India Shall not be taxed as Business Income under India – USA DTAA due to absence of PE: ITAT [Read Order]
The Income Tax Appellate Tribunal (ITAT) Delhi bench held that the Income from sub licensing software for the healthcare business in India should not be taxed under Business Income due to...
![Income from sub licensing software for healthcare business in India Shall not be taxed as Business Income under India – USA DTAA due to absence of PE: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/Income-sub-licensing-software-healthcare-business-India-Business-Income-India-USA-DTAA-PE-ITAT-TAXSCAN.jpg "Income from sub licensing software for healthcare business in India Shall not be taxed as Business Income under India – USA DTAA due to absence of PE: ITAT [Read Order]")
Income received from India by way of Royalties shall be taxed in India only on receipt basis under Indo-Switzerland DTAA: ITAT grants relief to ABB Switzerland [Read Order]
The Income Tax Appellate Tribunal (ITAT) Bangalore bench while granting relief to ABB Switzerland held that income received from India by way of Royalties should be taxed in India only on...
![Income received from India by way of Royalties shall be taxed in India only on receipt basis under Indo-Switzerland DTAA: ITAT grants relief to ABB Switzerland [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/received-India-Royalties-taxed-India-receipt-Indo-Switzerland-DTAA-ITAT-ABB-Switzerland-TAXSCAN.jpg "Income received from India by way of Royalties shall be taxed in India only on receipt basis under Indo-Switzerland DTAA: ITAT grants relief to ABB Switzerland [Read Order]")
Receipts from Reselling of Hardware and software packages are not 'Royalty' under India-Singapore DTAA: ITAT [Read Order]
The Income Tax Appellate Tribunal (ITAT) Delhi bench held that receipts from reselling of hardware and software packages are not “Royalty” under India Singapore Double Taxation Avoidance Agreement. ...
![Receipts from Reselling of Hardware and software packages are not Royalty under India-Singapore DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/08/Receipts-Reselling-Hardware-software-packages-Royalty-India-Singapore-DTAA-ITAT-TAXSCAN.jpg "Receipts from Reselling of Hardware and software packages are not Royalty under India-Singapore DTAA: ITAT [Read Order]")
Service Fees for Providing Supporting Services Taxable as FTS u/s 9(1)(vii) of Income Tax Act and Article 12(4) of India-USA DTAA: ITAT [Read Order]
The Mumbai Bench of Income Tax Appellate Tribunal (ITAT) held that the cost reimbursement of received by the assessee towards providing support services is taxable as fees for technical services both...
![Service Fees for Providing Supporting Services Taxable as FTS u/s 9(1)(vii) of Income Tax Act and Article 12(4) of India-USA DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/08/Service-Fees-Supporting-Services-Taxable-FTS-Income-Tax-Act-Article-India-USA-DTAA-ITAT-TAXSCAN.jpg "Service Fees for Providing Supporting Services Taxable as FTS u/s 9(1)(vii) of Income Tax Act and Article 12(4) of India-USA DTAA: ITAT [Read Order]")
Interest income covered under Article 8(3) of India-France DTAA not taxable for out of funds fixed deposits connected with aircraft under Article 8(1): ITAT Grants Relief to Air France [Read Order]
The Delhi bench of the Income Tax Appellate Tribunal (ITAT) held that the impugned income is not taxable in India as it is covered under Article 8(2) r.w. Article 8(1) of India-France Double Tax...
![Interest income covered under Article 8(3) of India-France DTAA not taxable for out of funds fixed deposits connected with aircraft under Article 8(1): ITAT Grants Relief to Air France [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/08/Interest-income-Interest-income-Air-France-DTAA-taxscan.jpg "Interest income covered under Article 8(3) of India-France DTAA not taxable for out of funds fixed deposits connected with aircraft under Article 8(1): ITAT Grants Relief to Air France [Read Order]")