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Income Tax - Country wise Withholding tax rate on Dividend (not being covered under Section 115-O), Interest, Royalty and Fee for Technical Services as updated with amendment carried out by Finance Act, 2017...
Read MoreIncome Tax - The Finance Bill 2017 proposes to amend sections 90 and 90A of the Act, to provide that where any 'term' used in an agreement entered into under sub-section (1) of Section 90 and 90A of the Act, is defined under the said agreement,...
Read MoreIncome Tax - Under the existing provisions of Section 90 of the Act, power has been conferred upon the Central Government to enter into agreement with the Government of any country outside India for granting relief in respect of income on which income-tax has been paid both under the said Act and income-tax Act in that foreign country...
Read MoreIncome Tax - Corporate India today serves global needs and brings in overseas income which is chargeable to Indian tax net as a resident of India. Flip side of this paves way for claim for taxes paid at foreign jurisdiction based on the source of income....
Read MoreIncome Tax - The Finance Act 2016 amended the provisions of section 206AA of the Income Tax Act, 1961 (‘Act’) with effect from 01.06.2016, thereby providing that the provisions of section 206AA would not apply to specified payments made to non-residents....
Read MoreIncome Tax - Finance Minister Shri Arun Jaitley signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting at Paris on 7th June, 2017 on behalf of India....
Read MoreIncome Tax - The Union Cabinet chaired by the Prime Minister Shri Narendra Modi has given its approval for signing of a Protocol amending the Convention between India and Portugal for avoidance of double taxation. The Protocol will also ensure prevention of fiscal evasion with respect to taxes on income....
Read MoreIncome Tax - Third Protocol amending India-Singapore Double Taxation Avoidance Agreement (DTAA) which was signed on 30.12.2016, has come into force on27.02.2017....
Read MoreIncome Tax - The Central Board of Direct Taxes (CBDT) has clarified that under the revised India-Korea Double Taxation Avoidance Agreement (DTAA), applications for bilateral Advance Pricing Agreement (APA) involving international transactions with Associated Enterprises in Korea for the APA period beginning Fiscal Year 2017-18 can be filed along with ...
Read MoreIncome Tax - The Protocol will broaden the scope of the existing framework of exchange of tax related information which will help curb tax evasion and tax avoidance between the two countries and will also enable mutual assistance in collection of taxes....
Read MoreCiticorp Investment Bank Vs DCIT (International Taxation) (ITAT Mumbai) - The ITAT Mumbai in Citicorp Investment Bank (Singapore) Ltd v. DCIT, held that the sale consideration received by a Singapore based Company on sale of debt instrument is not taxable as capital gain under the Income Tax Act in view of article 13(4) of the India-Singapore Double Taxation Avoidance Agr...
Read MoreDirector of Income Tax (IT)-I Vs A.P. Moller Marsk A S (Supreme Court of India) - Freight income from operation of ships in international waters is not chargeable to tax under Indo-Danish DTAA; Use of facility does not amount to technical services, as technical services denote services catering to the special needs of the person using them and not a facility provided to all....
Read MoreShell Global Solutions International BV Vs DDIT (ITAT Ahmedabad) - These appeals raise an interesting issue with respect to interplay of Article 9 of India Netherlands Double Taxation Avoidance Agreement and TP adjustments under domestic TP law....
Read MoreDDIT Vs Reliance Industries Ltd ( ITAT Mumbai) - Purchase of a license to use shelf/shrink-wrapped software is purchase of a product and not a copyright. Wherever the Government of India intended to include consideration for the use of software as ‘Royalties’, it explicitly provided so in the DTAA with the concerned country (e.g. India-Malaysi...
Read MoreAdobe Systems Incorporated Vs Assistant Director of Income Tax And Anr (Delhi High Court) - One of the necessary conditions for holding that an agent constitutes a PE of an enterprise is that the agent must have an authority to conclude contracts or should have been found to be habitually entering into or concluding contracts on behalf of the enterprise....
Read MoreNotification No. 82/2017- Income Tax/ S.O. 2826(E) - (30/08/2017) - S.O. 2826(E).—Whereas the Protocol amending the Agreement, signed at Ha Noi on the 7th day of September, 1994, between the Government of the Republic of India and the Government of the Socialist Republic of Viet Nam for the avoidance of double taxation and the prevention of fiscal evasion with res...
Read MoreNotification No. 18/2017-Income Tax / S.O. 935(E) - (23/03/2017) - Third Protocol amending the Agreement between the Government of the Republic of India and the Government of the Republic of Singapore for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income was signed at New Delhi on the 30th day of December, 2016 (h...
Read MoreNotification No. 10/2017-Income Tax - (14/02/2017) - Protocol amending the Convention and the Protocol between the Republic of India and the State of Israel for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income and on capital was signed at Jerusalem, Israel on the 14th day of October, 2015 (herei...
Read MoreNotification No. 03/2017-Income Tax - (10/01/2017) - Protocol between India and Cyprus for avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income ...
Read MoreInstruction No. 01/2017-Income Tax - (04/01/2017) - India-Sweden Convention for Avoidance of Double Taxation and Prevention of Fiscal Evasion (DTAC or Convention) - Suspension of Collection of Taxes during Mutual Agreement Procedure (MAP) ...
Read MoreNotification No. 82/2017- Income Tax/ S.O. 2826(E) - (30/08/2017) -
Citicorp Investment Bank Vs DCIT (International Taxation) (ITAT Mumbai) -
Notification No. 18/2017-Income Tax / S.O. 935(E) - (23/03/2017) -
Director of Income Tax (IT)-I Vs A.P. Moller Marsk A S (Supreme Court of India) -
