Income Tax : Form 41 is now compulsory for non-residents claiming DTAA benefits, replacing Form 10F. The update mandates online filing and ensu...
Income Tax : The Court held that indirect share transfers deriving value from Indian assets are taxable. Treaty benefits were denied due to tax...
Income Tax : Income Tax Department Ministry of Finance, Government of India DTAA & FTC Double Taxation Avoidance Agreement (DTAA) & For...
Income Tax : The case explains the statutory framework governing appeals and revisions under the Income-tax Act. It highlights the role of face...
Income Tax : The article explains how ESOP taxation spans salary, capital gains, DTAA, and disclosure requirements. It highlights that errors i...
Income Tax : India and France have signed a protocol granting full taxing rights on capital gains from share sales to the country of company re...
Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...
Income Tax : Explore challenges in TRC applications under DTAA by Indian companies. KSCAA proposes reforms for a simpler, efficient process. Le...
Income Tax : Explore the details of India's Double Tax Treaty with Cyprus, its signing date, benefits for both nations, tax recovery provisions...
Income Tax : Need for early amendment of DTAA regulations to stop the double taxation of Indian IT firms: Ms. Anupriya Patel tells the visiting...
Income Tax : The Delhi ITAT held that belated filing of Form No. 67 is only a procedural lapse and cannot extinguish substantive Foreign Tax Cr...
Income Tax : The Supreme Court affirmed that payments for cloud computing services are not royalty where no intellectual property rights are tr...
Income Tax : The Tribunal set aside the dismissal of a delayed appeal, holding that the issue of distribution fee taxability requires fresh exa...
Income Tax : The Tribunal held that consultancy payments for architectural services were not FTS since no technical knowledge was made availabl...
Income Tax : The tribunal held that gains from sale of shares did not fall under Article 14(4). It ruled that Article 14(6) applies, making gai...
Income Tax : The government enforced a tax collection assistance agreement with Japan effective from 8 July 2025. The notification enables cros...
Income Tax : The amendment expands the definition of permanent establishment to include service-based activities exceeding 183 days. It clarifi...
Income Tax : The Finance Ministry notifies the India-Belgium protocol amending the 1993 tax treaty, effective June 26, 2025, updating definitio...
Income Tax : Notification implements the India-Qatar Double Taxation Avoidance Agreement (DTAA) and Protocol, effective from the next fiscal ye...
Income Tax : Circular No. 01/2025 outlines the application of the Principal Purpose Test (PPT) under India's Double Taxation Avoidance Agreemen...
The Delhi ITAT held that belated filing of Form No. 67 is only a procedural lapse and cannot extinguish substantive Foreign Tax Credit rights under sections 90/90A/91 and applicable DTAAs. The Tribunal directed verification and grant of FTC where the form was filed before completion of assessment proceedings.
The Supreme Court affirmed that payments for cloud computing services are not royalty where no intellectual property rights are transferred. It held that mere access to services does not amount to use of equipment or technology under tax law.
The Tribunal set aside the dismissal of a delayed appeal, holding that the issue of distribution fee taxability requires fresh examination on merits. The case was remanded to the Assessing Officer for reconsideration with proper hearing.
Form 41 is now compulsory for non-residents claiming DTAA benefits, replacing Form 10F. The update mandates online filing and ensures standardized disclosure for availing treaty benefits.
The Tribunal held that consultancy payments for architectural services were not FTS since no technical knowledge was made available. Disallowance under Section 40(a)(i) was deleted.
The Court held that indirect share transfers deriving value from Indian assets are taxable. Treaty benefits were denied due to tax avoidance structure.
Income Tax Department Ministry of Finance, Government of India DTAA & FTC Double Taxation Avoidance Agreement (DTAA) & Foreign Tax Credit (FTC) Double Taxation Avoidance Agreement (DTAA) & Foreign Tax Credit (FTC) Introduction The Double Taxation Avoidance Agreement (DTAA) is an agreement between India and other countries to avoid double taxation, ensure the exchange of […]
The case explains the statutory framework governing appeals and revisions under the Income-tax Act. It highlights the role of faceless schemes in ensuring electronic filing, allocation, and disposal of appeals.v
The tribunal held that gains from sale of shares did not fall under Article 14(4). It ruled that Article 14(6) applies, making gains taxable only in the country of residence. The decision clarifies DTAA interpretation.
The government enforced a tax collection assistance agreement with Japan effective from 8 July 2025. The notification enables cross-border recovery of taxes, strengthening bilateral tax cooperation.
