S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Charges for management support services received by French Company-Not taxable in India-DTAA-India-France-Protocol 7 to double Taxation Avoidance Agreement Between India And France. [Art. 13]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for included services-Development and determination of short term business strategies-Payments not taxable-DTAA-India-USA. [Art. 12 (4)(b)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Non-resident-The payment made to the non-resident was a fee for training for developing soft skills-Not taxable in India-Entitled to refund of taxes paid together with interest-No treaty between India and Hong Kong during relevant period. [S. 248]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Mailbox hosting services and data canter services-Fees for technical services-Projects related services does not quality as fees for technical services-Payment received as business profits-No permanent establishment in India-Not taxable-DTAA-India-Singapore. [S. 9(1)(i), 9(1)(vi), 90 Art. 12 (4)(b)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Advertisement services-Royalty-advertisement space on website owned by foreign company (ESPN)-right to use of equipment (Server)-ESPN India was merely a reseller of advertisement space, consideration paid by ESPN India for purchase of advertisement space to ESPN, UK was not taxable as royalty-DTAA-India-UK. [S. 9(1)(vii), Art. 13]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Fees for Technical services-Right to use domain name which is in the nature of trade mark-Assessable as royalty-Web hosting services being ancillary to domain name registration services, consideration received had to be treated as FTS-DTAA-India-USA [S. 9(1)(vii), 115A, Art, 12(4)(a)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Software user fee-Selling standard software and not providing any licence to reproduce or make copies-Customers having only use of Copyrighted Article and no rights therein-Payments are not royalty-Not liable to deduct tax at source. [S. 9(1)(i), 195]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Consideration received for sale of software products-Not assessable as royalty-No permanent establishment in India-Net loss-Academic issue-DTAA-India-Finland. [S. 9(1)(vi), Expln.4. Art. 7(1)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Fees for technical services-Payment received from Indian from Indian hotels chargeable to tax in India.

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Fees for technical service-No material to substantiate that assessee transferred use or right to use copyright-Copyrighted articles-Additions not justified-DTAA-India-Singapore [Art.12(3), 12 (4)(b)]