#DTAA
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1,003 articlesIncome Tax

Income Tax
Income earned from offshore supply not taxable in India as none of operation is carried out in India
Income Tax

Income Tax
Application of GAAR Provisions cannot be a ground for denial of Tax benefit under India- Singapore DTAA
Income Tax

Income Tax
Sale of copyrighted article cannot be treated as royalty under Article 12(3) of India-USA DTAA
Income Tax

Income Tax
Provision of SAP and IT support service not covered within FTS is not taxable in India
Income Tax

Income Tax
Arbitration settlement amount received in relation to project office in India is taxable
Income Tax

Income Tax
Remuneration received for providing legal service not amount to ‘fees for technical services’
Income Tax

Income Tax
Analogy between UN, OECD Model Tax Convention and Indian Tax Treaties
Income Tax

Income Tax
If provisions of DTAA more beneficial then it supersedes provisions of income tax
Income Tax

Income Tax
Satellite Transmission Services cannot be treated as royalty
Income Tax

Income Tax
When software itself is not taxable, the training & related activities cannot be held to be FTS
Income Tax

Income Tax
Amount received for business support services not treatable as FTS
Income Tax

Income Tax
Brief understanding of Article 1 ‘Persons Covered’ of UN Model
Income Tax

Income Tax
Payment by GIPL to Google US towards seconded employees is outside purview of FTS/ FIS
Income Tax

Income Tax
