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DTAA with USA

Income Tax Case Laws, Section 195, Section 90

Kerala H.C : The appellant is entitled to take recourse to the provisions under the DTAA between India and USA, which are more beneficial than the provisions of the Income Tax Act, as stipulated under Section 90(2)

Avijit Das / August 9, 2018

High Court Of Kerala US Technology Resources (Pvt) Ltd. vs. CIT K. Vinod Chandran & Ashok Menon, JJ. Section 90(2), […]

Allahabad H.C : The Liaison Office (‘LO’) was engaged in marketing/ promoting appellant’s products in India, the appellant was liable to tax in India on business income

Avijit Das / November 11, 2014

High Court Of Allahabad Brown And Sharpe Inc. Vs. CIT Section : 9 Assessment Year 2003-04 Dr. Dhananjaya Yeshwant Chandrachud,

Section 9, Sec. 40(a)(i), Section 147, Section 195

Bombay H.C : There was any failure on part of assessee to provide all material facts, jurisdictional requirement for carrying out reassessment, after expiry of period of four years, was not fulfilled

Avijit Das / October 13, 2014

High Court Of Bombay Tao Publishing (P.) Ltd. vs. DCIT, Circle-7, Pune Section : 9, 40(a)(i), 195 And 147 Assessment

Delhi H.C : Where an assessee does not have any branch office or factory or workshop in India and merely because it has a subsidiary in India that by itself does not create a fixed place of business/location PE within meaning of article 5, paragraph 2, sub-clauses (b) to (k) of India-US DTAA

Avijit Das / February 5, 2014

High Court Of Delhi Director of Income-tax vs. E-Funds IT Solution Assessment Years : 2000-01 To 2002-03 And 2004-05 To

Section 92C, Section 92B

Delhi H.C : Where assessee was rendering installation and commissioning services to Indian customers and there was no agreement between Indian customers and U.S. Company in respect of same, said services could not be treated as international transactions and, hence, could not be considered for transfer pricing adjustment

Avijit Das / May 6, 2013

High Court Of Delhi CITâ€“IV vs. Stratex Net Works (India) (P.) Ltd. Section : 92B, 92C Badar Durrez Ahmed And

Section 195, Section 9

AAR : Income from other sources – Settlement amount to be paid in US suit for alleged tortuous act committed in India which is deposited in an initial escrow account in USA, is liable to TDS under section 195

Avijit Das / August 27, 2012

Authority For Advance Rulings (Income Tax), New Delhi Ic, In Re Section 9, 195 Justice P.K. Balasubramanyan, Chairman A.A.R. Nos.

Section 9, Section 195

AAR : The payment proposed to be made by the applicant towards payroll processing charges is taxable as per the provisions of Double Taxation Avoidance Agreement (“DTAA”) entered into between India and USA

Avijit Das / August 16, 2012

Authority For Advance Rulings (Income Tax), New Delhi Target Corpn. India (P.) Ltd., In Re Section : 9, 195 Justice

Section 195, Section 9

AAR : Where US company supplies and erects gas turbines offshore and also carry out repair and maintenance, amount related to inspection and boroscoping would not taxable in India

Avijit Das / May 30, 2012

Authority For Advance Rulings Solar Turbines International Company, In Re Section : 9, 195 Chairman P.K. Balasubramanyan A.A.R. No. 931

Section 9, Section 195

AAR : Payment by assessee to French company in consideration of receiving services in nature of assistance, professional and administrative consultation is fee for technical services liable to TDS under section 195

Avijit Das / April 16, 2012

Authority For Advance Rulings (Income Tax), New Delhi Mersen India (P.) Ltd., In Re Section 9, 195 P.K. Balasubramanyan A.A.R.

Bombay H.C : payment for merely supply of drawing , design not taxable as per DTAA between India & USA

Avijit Das / May 5, 2010

High Court Of Bombay Grasim Industries Ltd. Vs. S.M. Mishra, CIT Assessment Year : 1990-91 and 1991-92 Section : 9

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