S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Foreign agents-Introduction of students–Payment on account of evaluation of Ph.D thesis could not be treated as fees for technical service-Educating faculty and staff-Cannot be treated as managerial or technical services-Not liable to deduct tax at source-DTAA-India-Singapore. [S. 195, Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Computer software-Royalty-Agreements with distributors in India for supplying software products and for providing ancillary support services-Not royalty-DTAA-India-USA. [Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty Fees for technical services-Payment to non-resident-Consideration for resale/use of computer software through EULAs/distribution agreements, is not payment of royalty for use of copyright in computer software, and does not give rise to any income taxable in India-DTAA-India-Netherland-Portugal. [S. 9(1(vii), 195, Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty Principle of the most favoured nation (MFN)-Matter was remanded-DTAA-India-Belgium. [Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Subscription fees-Cloud computing infrastructure-Subscription fee was merely a consideration and would not be taxable as royalty-DTAA-India-USA. [Art. 12]

S. 9(1)(v) : Income deemed to accrue or arise in India-Interest-Loan provided to Indian parties-Not attributable to the permanent establishment-Interest income taxable at 10 per cent and not 40 per cent. [S. 9(1)(i), 154, Art. 7, 11(6), 14]

S. 9(1)(v) : Income deemed to accrue or arise in India-Interest-Rate of tax-Government securities-Interest income received on rupee-denominated bonds-Rate applicable at the rate of 5 per cent or 15 per cent-Matter remanded-Offshore distribution commission income-No permanent establishment-Commission is not taxable in India. [S. 9(1)(i), 115AD, Art. 7, 11]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Engineering services to its Indian subsidiary-Absence of PE-Receipt is not taxable-DTAA-India-Thailand. [Art. 7, 12, 22]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Dependent agent (DAPE)-Remuneration at arm’s length-Tax neutral-Addition was deleted-DTAA-India-USA. [Art. 5, 7]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Capital gains-Share transactions-Beneficial ownership-AO is directed to decide the issue by passing speaking order-DTAA-India-Mauritius. [Art. 13]