Income Tax - Companies register offshore for a variety of reasons, including tax benefits and financial privacy. Whether you need a company abroad depends on your specific business needs and goals....
Read MoreIncome Tax - Do you know, there are two principles to tax income. One is Residence Based Taxation and other is Source Based Taxation. As per Residence based Taxation, the country taxes persons based on their residential status....
Read MoreIncome Tax - Interpretation of term contracting states mentioned under DTAA between two countries. What do you mean by the term contracting states mentioned under DTAA? Sometimes It can be confusing when reading the definition of a contracting state under a DTAA for the first time, as it may be unclear which countries are being referred to as [&hellip...
Read MoreIncome Tax - The determination of residency is first step in the whole process of finalizing tax aspect of certain transaction. One need to ascertain that if any income is accrue/arise or deemed to accrue/arise in India in terms of Section 4,5 and 9 of Income tax Act....
Read MoreIncome Tax - ITAT held that payment received in India for providing logistics support services cannot be treated as royalty under Section 9(1)(vi) or fees for technical services under section 9(1)(vii) of Income Tax Act, 1961 ...
Read MoreIncome Tax - Need for early amendment of DTAA regulations to stop the double taxation of Indian IT firms: Ms. Anupriya Patel tells the visiting Deputy Premier of Western Australia Both sides acknowledge the need for an early ratification of Ind-Aus ECTA Australia to look into visa related issues of Indian students and tourists Minister of State (MoS) ...
Read MoreIncome Tax - The Union Cabinet, chaired by the Prime Minister Shri Narendra Modi has approved anAgreement between the Republic of India and Saint Vincent and The Grenadines for the Exchange of Information and Assistance in Collection with respect to Taxes....
Read MoreIncome Tax - CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SLOVAK REPUBLIC AGREEMENT FOR AVOIDANCE OF DOUBLE TAXATION AND PREVENTION OF FISCAL EVASION WITH – SLOVAK REPUBLIC Whereas a Agreement between the Government of th...
Read MoreIncome Tax - CBDT has released the synthesised text for India-Poland tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SYNTHESISED TEXT OF THE MLI AND THE CONVENTION BETWEEN THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THE REPUBLIC OF POLAND FOR THE AVOIDANCE OF DOUBLE TAXATION AND ...
Read MoreIncome Tax - CBDT has released the synthesised text for India-Australia tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. AUSTRALIA SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAXT REATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN ...
Read MoreBuro Happold Limited Vs DCIT (ITAT Mumbai) - ITAT Mumbai held that mere passing off project specific architectural, drawings and designs with measurements does not amount to making available technical knowledge, experience, skill, knowhow or processes. Accordingly, cannot be brought to tax as Fee for Technical Services....
Read MoreGoogle India Pvt. Ltd. Vs JDIT (ITAT Bangalore) - Purchase of online advertisement space for onward resale to Indian advertisers did not amount to Royalty as unless the non-resident, who was engaged in sale of online advertisement space, had a PE in India, no portion of receipts earned by it from sale of online advertisement space in India could be...
Read MoreS.R. Technics Switzerland Limited Vs ACIT (International Taxation) (ITAT Mumbai) - The LO does not constitute a fixed place through which business of assessee is carried out in India. Employees of the LO do not negotiate, finalise or discuss the mechanics of contracts including pricing with the assessee's customers. As such the employees of LO merely act as a communication link be...
Read MoreWTS Energy Dmcc Vs DCIT (Delhi High Court) - WTS Energy Dmcc Vs DCIT (Delhi High Court) Double Tax Avoidance Agreement obtaining between India and UAE does not contain any article concerning FTS. The petitioner, who is a non-resident and does not have a PE in India, claims that the subject income is “business income.” It is because of th...
Read MoreRohan Hattangadi Vs CIT (A) (ITAT Mumbai) - Rohan Hattangadi Vs CIT (A) (ITAT Mumbai) From Rule 128, it is evident that the assessee has to file Form 67 on or before the due date of furnishing the return of income as per section 139(1) of the Act, which the statement specifies as mandatory and not directory as per the word ‘shall’ used [&...
Read MoreCircular No. 3/2022-Income Tax - (03/02/2022) - The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (particularly to dividend withholding rates) available in the Protocol to some of the DTAAs with OECD member States. India's DTAAs with countries, namely Slovenia, Colombia an...
Read MoreNotification No. 135/2021-Income Tax [S.O. 5094(E)] - (08/12/2021) - Protocol amending the Agreement between the Government of the Republic of India and the Government of the Kyrgyz Republic for the Avoidance of Double Taxation and for the Prevention of Fiscal Evasion with respect to taxes on income signed at New Delhi on 13th April, 1999....
Read MoreNotification No. 29/2021-Income-tax [S.O. 1442(E).] - (01/04/2021) - CBDT notifies Agreement Between The Government Of The Republic Of India And The Government Of The Islamic Republic Of Iran For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income. Notification No. 29/2021-Income-tax Dated 1st April, 2021. MINISTRY OF...
Read MoreMAP GUIDANCE/2020 - (07/08/2020) - Though erstwhile rules 44G and 44H were in existence for a number of years, detailed information regarding MAP processes and guidance on issues related to such processes were not available in a comprehensive and consolidated manner....
Read MoreNotification No. 23/20020-Income Tax [G.S.R. 282(E)] - (06/05/2020) - Amendment of Mutual Agreement Procedure (MAP) procedure laid down in the Income-tax Rules, 1962 CBDT amends Rule 44G and Form 34F- Application to give effect to DTAA MINISTRY OF FINANCE (Department of Revenue) (CENTRAL BOARD OF DIRECT TAXES) Notification No. 23/20020-Income Tax New Delhi, the 6th...
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Buro Happold Limited Vs DCIT (ITAT Mumbai) -
Google India Pvt. Ltd. Vs JDIT (ITAT Bangalore) -
S.R. Technics Switzerland Limited Vs ACIT (International Taxation) (ITAT Mumbai) -
WTS Energy Dmcc Vs DCIT (Delhi High Court) -
Rohan Hattangadi Vs CIT (A) (ITAT Mumbai) -
CIT Vs Timken Company (Calcutta High Court) -
Michael Page International Pte Limited Vs DCIT (ITAT Mumbai) -
Standard Chartered Global Business Services Pvt. Ltd. Vs DCIT (ITAT Chennai) -