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New Fee for advertisements paid to Google and Yahoo not taxable in India, April 29, 2013

 

CBDT Circulars: more ambiguity than clarity, April 10, 2013

 

Transfer Pricing for advertising, marketing and promotional expenses : Tribunal lays down the law, February 20, 2013

 

Finance Minister announces 2 year breather from GAAR, January 15, 2013

 

Dividend distribution to reduce capital gains tax is permissible, November 27, 2012

 

Control and supervision’ - litmus test for taxability under Employees Secondment Arrangements - Bangalore ITAT, October 29, 2012

 

No Retro-tax on offshore M&A, recommends Shome Com, October 15, 2012

 

Government on reforms path, September 26, 2012

 

2.99 Cheers for GAAR Committee's Report, September 6, 2012

 

Fees Paid to Portfolio Managers Is Tax deductible: Tax Tribunal, August 28, 2012

 

Income taxable under both FTS and PE would be taxable as FTS: AAR; August 22, 2012

 

Advance Ruling Route to get embroiled in the Indian judicial process?, August 17, 2012

 

ITAT upholds that Distribution on Trust Dissolution not subject to tax in hands of Beneficiaries: Right conclusion, Wrong reason?, August 16, 2012

 

Share Transfer At Cost To Parent Company Not A Sham: ITAT Mumbai, August 13, 2012

 

No retrospective interpretation on amendments made to tax treaties: Amendment made to Article 7(3) of the Indo-UAE tax treaty to be applied prospectively, August 8, 2012

 

Tax-Free reorganisation not per se a Colourable device, says Bombay High Court, August 6, 2012

 

Taxation of Offshore Share Transfers, August 3, 2012

 

Breather for investment from Mauritius: AAR allows benefit of Mauritius treaty, July 23, 2012

 

No retroactive amendment to nullify a judgment: Gujarat High Court, July 11, 2012

 

Draft GAAR guidelines: More threatening than welcoming to foreign investors, July 3, 2012

 

'Gross Amount' Royalty under India-US DTAA includes amount paid as WHT: Income Tax Appellate Tribunal Delhi, June 21, 2012

 

No Indian tax payable on payment of brokerage fee to offshore reinsurer, June 06, 2012

 

Antidote for panic: FM announces delay of GAAR, May 14, 2012

 

Will a reassurance suffice a retrospective dilemma?; May 07, 2012

 

Investment Advisors and Investment Bankers not comparable rules Mumbai Tribunal, May 2, 2012

 

Making available ‘most favored nation’ benefits, April 30, 2012

 

Re-characterization of income to deny capital gains exemption under India Mauritius Treaty, April 27, 2012

 

Buy-Back by Indian Subsidiary results in Taxable Capital Gains, April 24, 2012

 

P- Notes: A story far from over, April 02, 2012

 

India Budget Insights 2012-13, March 17, 2012

 

All that is yours is mine?, February 14, 2012

 

Vodafone Victorious in Multi Billion Tax Battle, January 23, 2012

 

Payment made for 'Live Feed' of Cricket Matches Is Not Royalty: Income Tax Appellant Tribunal, Mumbai, December 28, 2011

 

Royalty-Free Grant of License in a Composite Settlement Agreement Treated as Amounting to Tax Avoidance, December 15, 2011

 

Sale of copyrighted article amounts to ‘royalty’ – Karnataka High Court, December 14, 2011

 

Mauritius Route, Not 'Objectionable Treaty Shopping': Recent Advance Ruling, November 30, 2011

 

Liaison Office Not Restricted to Purchase of Goods Subject to Permanent Establishment Exposure: AAR, October 3, 2011

 

Capital Gains from Listed Securities: No beneficial 10% tax rate for Non-residents, August 25, 2011

 

Taxing a Permitted Transferee: Any IDEAs?, July 21, 2011

 

Investments by Portfolio Managers result in Capital Gains, June 06, 2011

 

Tax authorities take E*Trade Mauritius to the Indian Supreme Court, May 6, 2011

 

Lifting of corporate veil in case of sale of shares between two non-residents, April 29, 2011

 

Tax return mandatory even when no tax payable in India, April 26, 2011

 

Regulatory checks and balances for Indian Wealth Managers : A boon, a burden, March 21, 2011

 

Transfer Pricing: Obligation to charge interest on overdue payments, March 10, 2011 

 

A 2nd opportunity to come clean, March 02, 2011

 

India Budget Insights 2011-12, February 28, 2011

 

No tax on LG Cables for the offshore component of turnkey project: Ishikawajma’s ruling echoed, Feb 18, 2011

 

Income from onsite development exempt only when carried out by offshore liaison office, February 3, 2011

 

Tribunal equates sale of land with transfer of rights in the land, January 28, 2011

 

Guarantee fees, a tax deductible expense - position guaranteed!, January 19, 2011

 

Importation of Active Pharmaceutical Ingredients under the transfer pricing radar, January 17, 2011

 

Transfer Pricing: No obligation to charge interest on overdue payments, January 12, 2011

 

No Application of Thin-Capitalization Rules Under Income Tax Act, 1961 Regime: ITAT, Mumbai, Dec 3, 2010

 

Reliance v. Microsoft: Tax Battle on Copyright; Nov 30, 2010

 

Payment for off-the-shelf software treated as royalty, Nov 12, 2010

 

No taxable income: No withholding tax : Rules Supreme Court, Sep 15, 2010

 

Vodafone decision: All is not lost, perhaps nothing, September 9, 2010

 

Déjà vu as India's Direct Tax Proposals enter Round 3, Sep 03, 2010

 

Branch of US educational institute required to apply 75% income in India, Aug 12, 2010

 

India-Singapore Treaty: Royalty Payments not Taxable in India Sans Economic Nexus with Permanent Establishment, July 30, 2010

 

SMR Ruling: Tax Department Attempts to Deny Treaty Benefits to Mauritius Company, July 29, 2010

 

Offshore services caught in the Indian tax net : the death of territorial nexus doctrine, July 27, 2010

 

Supreme Court Approves Dividend Stripping Transaction and Consequent Losses as Genuine, July 14, 2010

 

Common Issues Involving Indian Acquisitions, Dispositions and Spin-offs, June 21, 2010

 

Indian direct tax proposals revised: The good and the not so good, June 17, 2010

 

Aggregation of contracts: Geographical and Commercial Coherence essential to constitute Permanent Establishment says Tribunal, April 27, 2010

 

Relief comes the way of Indian importers: Chargeability a must for withholding of taxes, April 21, 2010

 

PAIN without PAN (Tax Identification Number)! Indian withholding tax to be 20% or higher, April 16, 2010

 

Valuation Rules Announced: Transact at Fair Market Value or Pay Taxes!, April 13, 2010

 

Unincorporated joint venture not held to be a taxable unit, April 8, 2010

 

Delhi High Court Sings Out of ‘Samsung’ Tune: No Withholding in India on Payments to Non-resident, March 30, 2010

 

FIIs: Not taxable in absence of permanent establishment, March 25, 2010

 

A Happy End to the E*Trade Mauritius Saga, March 24, 2010

 

Dutch company held taxable in India on account of goods purchased by Indian office, March 23, 2010

 

Foreign businesses with ‘no presence’ in India – Your logistics support provider could be a PE!, March 12, 2010

 

India’s first ruling on treaty ‘beneficial ownership’: Dutch company held not to be a conduit, March 09, 2010

 

Gift of shares of Indian company between non-residents not taxable in India – Is this still the case after the Budget?, March 03, 2010

 

India Budget Insights (2010-11), Feb 26, 2010

 

Characterization issues on assignment of rights to manufacture, Feb 24, 2010

 

BBC Worldwide (India) paid on arm's length basis - No further attribution, Feb 09, 2010

 

Comprehensive Architectural Services regarded as “Technical” Services, Feb 06, 2010

 

“No free loans!” say Indian Transfer Pricing authorities, Feb 05, 2010

 

Tax free import of software into India, Feb 03, 2010

 

Double Non-Taxation not to debar treaty benefits: Recent Tribunal ruling, Feb 02, 2010

 

The STAR Amalgamation: No Indian tax liability for transfer of shares / assets, Jan 27, 2010

 

Outbound payments for quality-control testing services held taxable in India, Jan 23, 2010

 

Payment for non-exclusive Right to Use know how Taxable as Royalty: Authority for Advance Rulings, Jan 05, 2010

 

Supreme Court provides a breather for withholding tax obligations on payments made to non-residents, Dec 28, 2009

 

Ambiguity In Valuation Of Employee Stock Options Removed – Government Issues Valuation Norms For Taxation Of Perquisites, Dec 23, 2009

 

Would remittance for every import be now subject to withholding tax?, Nov 19, 2009

 

No objection to FDI from Mauritius: FIPB, Nov 11, 2009

 

Payments to Group Company for assistance with day-to-day operations held to be ‘Fees for Technical Services’, Nov 02, 2009

 

Revenue may attribute higher income to non-resident's India connection- Withdraws important circular 23 of 1969, Oct 28, 2009

 

Payments for use of satellite transponders held to be “royalty”, Oct 23, 2009

 

Client confidentiality privilege: Only for lawyers and not for accountants, Oct 21, 2009

 

Swiss tax treaty benefits not to apply to shipping profits: Recent advance ruling, Oct 12, 2009

 

Construction contracts get relief: Work done by subcontractor in India not to result in a PE for German contractor, Sep 25, 2009

 

Legal fees payable to foreign firm held taxable in India, Sep 17, 2009

 

‘Technically’ Correct: ‘Make Available’ Requirements to be met for Classification as ‘Fees for Technical Services’, Sep 14, 200

 

New Indian Direct Tax Code to adversely impact cross-border M&A, Aug 13, 2009

 

The Rising Popularity of Advance Rulings in India, July 21, 2009.

 

Getting connected but avoiding the tax loop, July 15, 2009.

 

Subscription fees for accessing online data base held not to be royalty income, July 13, 2009.

 

Construction PE: Duration of preparatory activities included for determining PE existence, July 10, 2009.

 

AAR Opines on Indian Taxation of Off-Shore Contracts and Related ‘Association of Persons' Issues, June 25, 2009.

 

Tax Authorities Shed Light On Taxation Of Composite Contracts Having Separate Identifiable Segments, June 17, 2009

 

Liaison Office in India? Beware of permanent establishment issues! June 3, 2009

 

E*Trade Mauritius Uproar - Tax Department’s Findings (An Update), April 29, 2009

 

Partnership as a tax planning tool—Advance Ruling says “Yes”, April 28, 2009

 

The established principle of territorial nexus questioned by the AAR, April 21, 2009

 

E*Trade and the Mauritius route: Much ado about nothing? April 20, 2009

 

Expat salaries: Supreme Court expands scope of withholding tax on split salaries, March 28, 2009

 

Revenue Clarifies Tax Credit Rules: VC/PE, Pharma, Media and Other Industries to Benefit, March 24, 2009 

Lucent Technologies: License of software held to be business income, March 19, 2009

Software Taxation: AAR refuses to entertain Microsoft’s application,  March 4, 2009

Service exporters get headache pill : CBEC introduces clarifications on export of service, February 27, 2009

PE auxiliary activity exclusion: High Court adopts a liberal approach, February 21, 2009

Taxation of Mauritius cell companies examined, February 13, 2009

Earn outs taxed as salary! new challenges in M&A structuring…, February 4, 2009

Justice and the Due Process of Law: The Vodafone saga continues, February 3, 2009

Enigma of Software taxation: Royalty or Business Income? January 19, 2009

Deputation of supervisory personnel not to create PE in India, January 15, 2009

AAR wishes Ikea’s Indian Liaison Office a tax free New Year, January 5, 2009

 

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