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]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Annual Maintenance Contract with an Indian Co-Not to constitute either a fixed place PE or agency PE business profit of assessee could not be taxed in India-DTAA-India-Singapore. [Art. 5, 8]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Permanent establishment-Agency PE-Agent is paid arm’s length remuneration-Tax neutral-Not taxable-DTAA-India-Singapore. [Art. 5]