The ITAT clarified that Article 13(3A) applies strictly to shares and not to derivative instruments. It held that derivative gains fall under residual provisions and are taxable in the resident country. The ruling emphasizes correct interpretation of DTAA provisions.
ITAT Chennai ruled that translation services are not “technical services” under Section 9(1)(vii), leading to the deletion of a disallowance under Section 40(a)(i) for non-deduction of TDS on payments to non-resident translators.
ITAT Delhi rules Coursera’s income from Indian customers not taxable as Fees for Technical Services (FTS) under India-USA DTAA. A key decision for online platforms.
Learn about the tax dispute between Diamond Manufacturing Management and the Indian Revenue Authority, involving fees for technical collaboration and the absence of Permanent Establishment.
Supreme Court clarifies Section 80HHC deduction for Export-Oriented Units, emphasizing that profits eligible for deduction must be directly derived from the export of goods. Gain from foreign exchange fluctuations, in this case, ruled as not qualifying for deduction. Stay informed on crucial tax rulings.
Read about Supreme Court’s decision in US Technologies case regarding TDS penalty under Section 271C of Income Tax Act, 1961, for delayed remittance.
