• Service: Tax, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 7/21/2014

India - Japanese entity conducts trading activities, not service provision 

July 21: The KPMG member firm in India has prepared the following reports (click on the hyperlinks below to read more).
  • Japanese trading intermediary (Sogo Shosha) conducts trading activities, not provision of service - The Delhi High Court held that the taxpayer’s activities as a trading intermediary (in Japanese, “Sogo Shosha”) are akin to those of a trader and not a service provider.

    The case is: Mitsubishi Corporation India Private Ltd. Read a July 2014 report(PDF 445KB)

  • Withholding tax and the effect of retroactive changes concerning the payment of placement fees - The Mumbai Bench of the Income-tax Appellate Tribunal held that a payment made by the taxpayer towards placement charges is not a “royalty” under provisions of the Income-tax Act, 1961, and that changes that apply retroactively do not apply because the taxpayer withheld tax at source.

    The case is: NGC Networks (I) Pvt. Ltd. Read a July 2014 report(PDF 474KB)

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