During the years under consideration, it had deputed its pilots and cockpit crew to non-resident companies for training on flight simulators. The ITAT held that since hiring of simulator by itself has no purpose, fee paid for simulator is not royalty. Further, in absence of FTS article in India-UAE DTAA, it was to be treated […]
ULO SYSTEMS LLC V DCIT (2019) 105 TAXMANN.COM 259 (DELHI TRIBUNAL); TS-164-ITAT-2019(DEL)
Equipment was placed and personnel were stationed on the vessel of the main contractor for carrying out grouting work. The ITAT held that the vessel was a fixed place of business through which the assessee carried on business Facts: The Assessee is a company incorporated in UAE. The Assessee is carrying on grouting services in […]
MEANING OF TERM INTEREST AS PER SECTION 2(28A) OF THE INCOME TAX ACT, 1961
Section 2(28A) of the Income Tax Act, 1961 defines the term ”interest” to mean interest payable in any manner in respect of any moneys borrowed or debt incurred (including a deposit, claim or other similar right or obligation) and includes any service fee or other charge in respect of the moneys borrowed or debt incurred […]