A. DATA PROCESSING USING MAIN FRAME COMPUTER LOCATED ABROAD NOT TAXABLE

B. INCOME FROM BRANCH-HO TRANSACTIONS TAXABLE IF SAME ACCRUES/ARISES IN INDIA

C. EXISTENCE OF PE AT THE TIME OF RECEIPT OF INCOME NOT NECESSARY FOR TAXABILITY

D. DOWNLINKING SERVICES NOT LIABLE TO TAX IF NO PE EXISTS

E. TDS PAYMENT NOT ALLOWABLE AS DEDUCTION IF NO CONTRACTUAL LIABILITY

F. TRAINING FEES PAID IN RESPECT OF KNOW-HOW TAXABLE IN INDIA

G. ONUS OF PROVING THAT DEBT HAS BECOME BAD DOES NOT REST ON THE ASSESSEE

H. FOREIGN ENTITY SUPPLYING "SHRINK WRAP" S/W FOR RESALE NOT LIABLE TO TAX

I. LONG TERM CAPITAL LOSSES CAN BE SET OFF AGAINST SHORT TERM CAPITAL GAINS

J. DETAILS OF EXPS. NOT NECESSARY UNLESS ALLOWANCE IS DISPROPORTIONATE

K. PURCHASE OF DESIGNS FROM ABROAD NOT TO ATTRACT WITHHOLDING TAX

L. CONSULTANCY SERVICES OF NON-TECHNICAL NATURE ARE NOT TAXABLE

M. SPECIFIC PROVISIONS OF DTAA TO OVERRIDE GENERAL PROVISIONS OF DTAA

N. WITHHOLDING TAX OBLIGATION ON TELECASTING COMPANY

O. ACTUAL PAYMENT OF TAX NOT A PREREQUISITE FOR CLAIMING DTAA BENEFITS

P. ENHANCEMENT OF TAX LIBILITY BY ITAT

Q. LIAISION OFFICE OF WESTERN UNION NOT A PE & HENCE NOT LIABLE TO TAX

A. PAYMENT FOR DATA PROCESSING USING MAIN FRAME COMPUTER LOCATED ABROAD NOT TAXABLE
B. INCOME FROM BRANCH-HO TRANSACTIONS TAXABLE IF SAME ATTRIBUTABLE TO BUSINESS CARRIED OUT IN INDIA
C. EXISTENCE OF PE AT THE TIME OF RECEIPT OF INCOME NOT NECESSARY FOR TAXABILITY
D. DOWNLINKING SERVICES NOT LIABLE TO TAX IF NO PE EXISTS
E. TDS PAYMENT NOT ALLOWABLE AS DEDUCTION IN THE ABSENCE OF CONTRACTUAL LIABILITY
F. TRAINING FEES PAID IN RESPECT OF KNOW-HOW TAXABLE IN INDIA AS KNOW-HOW NOT A "PROPERTY" FOR DTAA
G. ONUS OF PROVING THAT DEBT HAS BECOME BAD DOES NOT REST ON THE ASSESSEE
H. FOREIGN ENTITIES SUPPLYING "SHRINK WRAP" SOFTWARE FOR RESALE NOT LIABLE TO PAY TAX IN INDIA
I. LONG TERM CAPITAL LOSSES CAN BE SET OFF AGAINST SHORT TERM CAPITAL GAINS (A.Y. 1988-89 TO 2002-03)
J. DETAILS OF EXPENSES NOT NECESSARY UNLESS ALLOWANCES ARE UNREASONABLE/DISPROPORTINATE
A.K. PURCHASE OF DESIGNS FROM ABROAD NOT TO ATTRACT WITHHOLDING TAX
L. CONSULTANCY SERVICES OF NON-TECHNICAL NATURE ARE NOT TAXABLE
M. SPECIFIC PROVISIONS OF DTAA TO OVERRIDE GENERAL PROVISIONS OF DTAA
P. ENHANCEMENT OF TAX LIABILITY BY ITAT
 
   
   
 
 

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