Saturday International Tax Gyan!! #taxmadeeasy #taxinpic Protocols in DTAA, elaborate and complete the text of a treaty, sometimes even altering the text. [Steria (India) Ltd. v. Commissioner of Income-tax-VI] [2016] 72 taxmann.com 1 (Delhi))
Saturday International Tax Gyan!! #taxmadeeasy #taxinpic Non-Compete fees paid to employees who were rendering service outside India would be considered as salary and hence not taxable in India. [Director of Income-tax v. Sasken Communication Technologies Ltd.] [2020] 117 taxmann.com 278 (Karnataka)
Saturday International Tax Gyan!! #taxmadeeasy #taxinpic Agreement with Indian company for management support service, accounting etc. where no transfer of technology and ‘make available’ clause not satisfied, hence not taxable [Inter Continental Hotels Group (Asia Pacific) (Pte.) Ltd. v. ACIT, Circle-2(1)(1), New Delhi]
Saturday International Tax Gyan!! #taxmadeeasy #taxinpic In absence of separate article of FTS in DTAA, such income shall be considered as business income and in absence of PE in India non resident is not required to pay tax in India. [Paramina Earth Technologies Inc v. Deputy Commissioner of Income-tax (International Taxation), Visakhapatnam [2020] 116 taxmann.com 347 (Visakhapatnam …
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