Saturday International Tax Gyan!! (SITG-181) #taxinpic #taxmadeeasy Standard and automated service provider by the online service provider cannot be covered under FTS Amazon Web Services, Inc. v. ACIT (International Taxation)
Saturday International Tax Gyan!! (SITG-180) #taxinpic #taxmadeeasy Assumption of ‘jurisdiction’ to be decided at the outset in case of non-resident entity Cricket South Africa (NPC) vs. ACIT (International
Saturday International Tax Gyan!! (SITG-179) #taxinpic #taxmadeeasy Foreign assignment allowance received by assessee for service outside India is not taxable in India. Durga Prasad Sana VS. Income-tax officer
Saturday International Tax Gyan!! (SITG-178) #taxinpic #taxmadeeasy Under India Germany Treaty Royalty is taxable on receipt/ cash basis and not on accrual basis. M/s Faber Castell Aktiengesellschaft Vs ACIT (IT)
Saturday International Tax Gyan!! (SITG-177) #taxinpic #taxmadeeasy A person acting as a guarantor cannot be held liable for deducting TDS on payment made by the person in relation to whom guarantee has been given. Ingram Micro Inc Vs DCIT
Saturday International Tax Gyan!! (SITG-176) #taxinpic #taxmadeeasy Amount received for domain name registration is considered as Royalty and amount received for web hosting service will be considered as FTS as per DTAA as well GoDaddy.com LLC Vs. DCIT
Saturday International Tax Gyan!! (SITG-175) #taxinpic #taxmadeeasy Payment made to non resident for technical services rendered outside India in relation to export by an Indian company would not fall within exception to FTS u/s 9(1)(vii)(b) Cadila Healthcare Ltd. Vs DCIT (IT) – 1
Saturday International Tax Gyan!! (SITG-174) #taxinpic #taxmadeeasy Amount received by an assessee for sale of software and its support services will not be taxable as Royalty or FTS under DTAA BMC Software Asia Pacific Pte Ltd. Vs ACIT (IT)
Saturday International Tax Gyan!! (SITG-173) #taxinpic #taxmadeeasy An assessee can be considered as a resident of a country for a part of a year and Non resident for other part of year based on a tie breaker rule Narinder Pal Singh Vs ACIT
Saturday International Tax Gyan!! (SITG-172) #taxinpic #taxmadeeasy In case of CCPS, for India Mauritius Treaty date of issue/acquisition of CCPS shall be considered as date of acquisition of converted equity shares
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