vs DCIT examines the taxability of certain non-resident television channel companies telecasting programmes from outside India. It would acquire advertisement airtime from various non-resident television channel companies, and in-turn, would sell the airtime to various Indian advertisers, through its ...
Ruling on taxability of fixed recurring charges paid to a non-resident for use of telecoms bandwidth.The article discusses a court case wherein the Authority for Advance Rulings (AAR) in India examined the taxability of fixed recurring charges paid to a non-resident for the use of ...
Assessment of tax With regard to the basis of assessment of tax, the principle of equal treatment normally has the following implications: (a) Permanent establishments must be accorded the same right as resident enterprises to deduct the trading expenses that are, in general, authorized by the ta...
(i.e., that of the Philippines and the Non-Resident Foreign Corporations). Further, the services are to be viewed in their entirety and not as a single or compartmentalized particular activity as the income producing activity, in consonance with the Civil Code provisions on the perfor...
Italy: Non-Taxability of Royalties Paid to Non-Resident Companiesdoi:10.54648/taxi1980077G. MaistoIntertax
The Court acknowledged and held that the taxability of a non- resident in India is restricted to only such profits that accrue or arise or deemed to accrue or arise in India; hence there is the artificial divisions of income between profits earned in India and outside India. The Court ...
Stacey DelichGould
The Mumbai bench of the income tax appellate tribunal (ITAT) in India examined the case, focusing on the taxability of fees paid to a non-resident for conducting a market study. The ITAT analyzed the provisions of article 12(4)(b) of the double taxation avoidance treaty with Singapore ...
vs CIT. The Uttarak-hand high court (HC) in India examined the taxability of mobilisation fee received by a non resident taxpayer. The taxpayer had entered into an agreement with an Indian company for supply and operation of drilling units/rigs on hire. The HC held that the mobilisation ...
Ltd. to Yahoo US and Google Ireland for online advertising services. It states that business profits, under tax treaties, cannot be taxed in India if earned by a non-resident (NR).NayakErnstRajendraErnstJainErnstAasthaErnstInternational Tax Review...