CS : Computer Software ITA : Indian Income Tax Act Software Royalty – Judicial Dilemma: [2005] Motorola Case Special Bench ITAT Delhi- COMPUTER SOFTWARE being ‘Copyrighted’ article not ‘copyright’ Not taxable both under ITA and relevant DTAA. [2010] Gracemac …
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read moreRoyalty – Under ITA Abbreviations used: ITA : Indian Income Tax Act WHT : Withholding Tax Royalty is generally a consideration received by a person – a creator or an innovator for allowing his work of art or …
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read moreFee for Technical Services (FTS) – Under Tax Treaty Abbreviations used: FTS : Fee for Technical Services ITA : Indian Income Tax Act OECD : Organization for Economic Co-operation and Development UN : United Nations The tax …
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read moreFee for technical Services (FTS) – Under ITA Abbreviations used: FTS : Fee for technical Services ITA : Indian Income Tax Act Taxability of Fee for technical Services as per ITA Section-9(1)(vii) of ITA provide that Non-residents are …
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read moreTax Treaty – Exchange of Information Abbreviations used: AEOI : Automatic Exchange of Information AML : Anti Money Laundering BEPS : Base Erosion Profit Shifting CFT : Combating the Financing of Terrorism CRS : Common …
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read moreA Perspective : In the last four papers, we have discussed taxability of Non-Residents in India as per Indian Income tax Act and the relief available under tax treaties on doubly tax income and controversies relating to residential status and …
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read moreApplication of Tax Treaty- In the last three papers, we have discussed taxability of Non-Residents in India as per Indian Income tax Act and the relief available under tax treaties on doubly tax income and controversies relating to residential status …
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read moreIn the last two papers, we have discussed tax ability of Non-Residents in India as per Indian Income tax Act and the relief available under tax treaties on doubly tax income. As determination of tax and computation of relief is …
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read moreIn our previous paper, we have discussed the tax ability of Non-Residents under Indian Income Tax Act. In this paper, we are discussing how tax treaties assist avoiding double tax on the same income; one, at source Country and another …
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read moreIn the advent of global trade large number of cross border transactions are taking place in India and a huge amount of payments are being made to non-residents. Tax on Income earned by non-residents from such transactions which is chargeable …
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