S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Training services-Installation and supervision fee was made by assessee to sub-contractor at Belgium-Entitled to claim benefit of restricted definition of fee-DTAA-India-Portugal.[S. 9(1)(vi), Art. 12]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Marketing services-Related services to hotels-Distinct and different from license fee-Not to be assessed as FTS-Reimbursement of cost received cannot not be treated as FTS-DTAA-India-Singapore [Art. 12(4)(a)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Income on account of rendering business support services from Indian-company-Not assessable as FTS-DTAA-India-Netherland.[S.9(1)(vi), Art.12(5)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Reimbursement of expenses would not constitute royalty-Not taxable in India-DTAA-India-USA [Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Consideration received for Satellite Transmission Services-Not taxable as royalty-DTAA-India-USSA. [Art. 12(3)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Sale of software-Not transferred use or right to use of any copyright in software-Cannot be treated as royalty-India-USA. [Art. 12(3)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Consideration for resale/use of computer software through EULAs/distribution agreements, is not payment of royalty for use of copyright in computer software, and same does not give rise to any income taxable in India-standard automated services to Indian customers-Matter remanded-DTAA-India-Ireland [S. 9(1)(vii), Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Sale of advertisement space through its AdWords program could not be brought to tax in India as royalty-Not parted with copyright-DTAA-India-Ireland.[S. 147, 148,201, 201(IA), Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Payments were made to UAE company to carry out services of project specification study, preparation of tower designs, preparation of structural drawings of tower, preparation of tower test data documents etc.-Not royalty-Not liable to deduct tax at source-DTAA-India-UAE. [S. 201(1), 201(IA), Art. 7, 12]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Limited Liability Partnership (LLP) and tax resident of UK-legal services to its clients worldwide-Entitled to benefit of article 4(1) of India-UK DTAA in respect of income generated from professional services rendered in India which had been taxed in UK-providing legal services to its client worldwide was not FTS-Employees of assessee, non-resident LLP, for rendering services in India stayed for only 17 days-Independent personnel services or independent activity-DTAA-India-UK [S.9(1)(vii), Art. 4(1), 5, 13, 15]