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DTAA - Deployment of 'sofware' lacks physical attributes which underlie and constitute integral part of concept of Permanent Establishment: HC (See Breaking News)

DTAA - Subscription fee charged by non-resident entity for granting access to database would clearly not amount to transfer of 'right to use copyright', and hence not taxable as royalty: ITAT (See Breaking News)

TP - Overseas AEs can be treated as tested parties, after considering global transfer pricing report of foreign AEs: ITAT (See Breaking News)

I-T - Since no business activity is carried out by assessee during relevant period through LO and no expat employee were engaged by assessee at LO, assessee ceases to have any PE or DAPE in India: ITAT (See Breaking News)

DTAA - Non-resident assessee is eligible for choosing beneficial provisions provided under domestic law and carry forward same without setting off against long term capital gain for subsequent years: ITAT (See Breaking News)

DTAA - Rule 128(9) does not preclude assessee from claiming Foreign Tax Credit (FTC) in case of delay in filing ITR, as the FTC is a vested right of assessee: ITAT (See Breaking News)

I-T - Payment made overseas for services rendered abroad, is not deemed income u/s 9, and hence not liable to TDS u/s 195: ITAT (See Breaking News)

DTAA - Compensation received by non-resident assessee, pursuant to Arbitral Award, for non-payment of dues for offshore supplies made, would have to be construed only as its business income: ITAT (See Breaking News)

INTL - Re-assessment in cases involving tax amounts under Rs 50 Lakhs have to be completed within 3 years, failing which any order is barred by limitation: ITAT (See Breaking News)

TP - Assessee's claim against reversal of provision for inventory written off due to obsolescence, is allowable, since the same is offered to tax in the year of creating the provision: ITAT (See Breaking News)

DTAA - Where ITR is filed within the extended due date and the tax payable after TDS credit is nil, interest under section 234A cannot be levied: ITAT (See Breaking News)

I-T - If interpretation of residence country about applicability of treaty provision is not same as that of source jurisdiction and yet source country levies taxes by way of tax withholding, tax credit can't be declined: ITAT (See Breaking News)

I-T - If remittance made to foreign subsidiary are held to be not taxable in India in hands of recipient company in India, there would be no obligation for payer to deduct tax at source u/s 195: ITAT (See Breaking News)

I-T - Wherever Contracting States to tax treaty intend to extend treaty protection to domestic company paying DDT, only then domestic company can claim benefit of DTAA, if any: ITAT (See Breaking News)

I-T - Long-term capital gains arising during relevant previous year are exempt from tax in terms of Article 13 of respective DTAAs, then provisions of Sect 74 of I-T Act would not get triggered: ITAT (See Breaking News)

DTAA - In absence of bilateral amendment to DTAA, OECD Commentary guides interpretation of royalty, particularly in cases where payments for digital transactions resembles royalty or technical services: ITAT (See Breaking News)

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