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Income Tax - Certain income of non-resident, inter-alia, dividend, interest, royalty or fees for technical services shall be taxable as per the rates prescribed under the Income-tax Act or as per the rates prescribed under the DTAAs, whichever is more beneficial to such non-resident. ...
Read MoreIncome Tax - Country wise Withholding tax rate on Dividend (not being covered under Section 115-O), Interest, Royalty and Fee for Technical Services ...
Read MoreIncome Tax - Nowadays on account of the globalized environment and expansion of business outside India, a person may earn income from more than one country and sometimes the same income may be taxed twice, once in the source country and other in the resident country as well. Let us know these two methods for taxing income earned by a person in more de...
Read MoreIncome Tax - Objective Part – 1 – Impact on domestic trade The Author, in this article, discusses the impact of recent decision of Supreme Court [SC] in the case of Engineering Analysis on domestic laws and concludes that equalisation levy will be payable on import of computer software provided the conditions are fulfilled and some impact due [&he...
Read MoreIncome Tax - This article seeks to highlight certain key differences between the Special Economic Zone (SEZ) units, Export Oriented Units (EOU) and Domestic Tariff Area (DTA) units[1] in terms of their various benefits and compliances from an indirect tax point of view. Subject SEZ Unit EOU Unit DTA Unit Area of operations / Setting Up Can be [&hellip...
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 MoreIncome Tax - CBDT has released the synthesised text for India-Singapore tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAX TREATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN THE GOVERNME...
Read MoreIncome Tax - CBDT has released the synthesised text for India-Austria tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. AUSTRIA SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAX TREATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE CONVENTION BETWEEN THE G...
Read MoreTrimble Solutions Corporation Vs DCIT (ITAT Mumbai) - Income from cloud hosting services is erroneously held as royalty within the meaning of explanation 2 to section 9(l)(vi) of the Income Tax Act, 1961 (the Act) as well as Article 12(3)(b) of the India - US tax treaty...
Read MoreGoldman Sachs India Investments (Singapore) PTE Limited Vs DCIT (ITAT Mumbai) - The provisions of the DTAA cannot be thrusted upon the Assessee simply because the Assessee is a tax resident of a country with which India has entered into a tax treaty or on account of the mere perception of the AO that the Assessee may claim benefits under the tax treaty in subsequent years. 2. S...
Read MoreSri Vamsee Krishna Kundurthi Vs ITO (International Taxation) (ITAT Hyderabad) - Sri Vamsee Krishna Kundurthi Vs ITO (International Taxation) (ITAT Hyderabad) As the assessee has spent less than 60 days in India during the FY 2013-14, he qualifies as a Non resident under section 6(1) of the Act. Therefore, the foreign allowance of Rs.19,79,072/- was not offered to tax in India i...
Read MoreRanjit Kumar Vuppu Vs ITO (ITAT Hyderabad) - Ranjit Kumar Vuppu Vs ITO (ITAT Hyderabad) This is assessee’s appeal for the A.Y 2014-15 against the order of the CIT (A)-10, Hyderabad, dated 14.07.2020. 2. Brief facts of the case are that the assessee, a Non-resident individual, filed his return of income for the A.Y 2014-15 on 31.07.2014 admit...
Read MoreDevice Driven (India) Pvt. Ltd. Vs CIT (Kerala High Court) - Device Driven (India) Pvt. Ltd. Vs CIT (Kerala High Court) No TDS on commission paid to non-resident agent for effecting exports as it was not taxable under Income Tax Act Conclusion: Services rendered for effecting exports within India by assessee-company to foreign buyers would not attract income ...
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...
Read MoreNotification No. 22/2020-Income Tax [S.O. 1370(E)] - (24/04/2020) - Protocol Between The Government Of The Republic Of India And The Government Of The Republic Of Austria Amending The Convention For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income, Which Was Signed At Vienna On 8 November, 1999...
Read MoreNA - (17/03/2020) - The Agreement between the Government of the Republic of India and the Government of Brunei Darussalam for the exchange of information and assistance in collection with respect of taxes (hereinafter referred to as the Agreement), was signed in New Delhi, India on 28th of February, 2019. The Agreement...
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Trimble Solutions Corporation Vs DCIT (ITAT Mumbai) -
Goldman Sachs India Investments (Singapore) PTE Limited Vs DCIT (ITAT Mumbai) -
Sri Vamsee Krishna Kundurthi Vs ITO (International Taxation) (ITAT Hyderabad) -
Ranjit Kumar Vuppu Vs ITO (ITAT Hyderabad) -
Device Driven (India) Pvt. Ltd. Vs CIT (Kerala High Court) -
Notification No. 29/2021-Income-tax [S.O. 1442(E).] - 01/04/2021
