Income Tax : CIT – International Taxation Vs. ESPN Star Sports Mauritius S.N.C ET Compagnie (Delhi High Court) The Delhi HC affirms the o...
Income Tax : Explore the India-USA Tax Treaty, its provisions, implications, and how it prevents double taxation. Learn about residency, taxati...
Income Tax : Understanding Foreign Tax Credit (FTC) in India: Learn its significance, rules, claiming procedure, case law insights, and steps t...
Income Tax : Learn the essentials of Form 10F filing for non-residents seeking DTAA benefits in India, including required documents, filing pro...
Income Tax : Understand Form 15CA/15CB and their filing process for cross-border transactions. Ensure compliance and transparency in internatio...
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 Union Cabinet, chaired by the Prime Minister Shri Narendra Modi has approved anAgreement between the Republic of India and Sa...
Income Tax : CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modif...
Income Tax : CBDT has released the synthesised text for India-Poland tax treaty. It represents their shared understanding of the modifications ...
Income Tax : ITAT Mumbai held that disallowance made u/s. 14A of the Income Tax Act read with rule 8D deleted as tax free funds were more than ...
Income Tax : ITAT Bangalore held that payment made by Google India Pvt. Ltd. to Google Ireland Limited (assessee) for sale of online advertisem...
Income Tax : Analysis of ITAT Delhi's ruling: Sale of software products not taxable as royalty under India-Japan DTAA, citing Engineering Analy...
Income Tax : ITAT Delhi held that expense towards management and marketing support service paid to foreign company is not taxable under Fee for...
Income Tax : Discover the ITAT Delhi ruling on taxing income from providing business support services to Indian group entities. Analysis of Sol...
Income Tax : Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and ch...
Income Tax : Explore implications of Notification No. 21/2024 from Indias Ministry of Finance regarding the tax information exchange pact with ...
Income Tax : Notification No. 96/2023-Income Tax: Learn about the agreement between India and Saint Vincent for tax information exchange and as...
Income Tax : Notification No. 24/2023- Income-Tax Dated: 03rd May, 2023 under section 90(1) of Income tax Act, 1961 regarding Agreement and Pro...
Income Tax : The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (part...
ITAT Mumbai held that disallowance made u/s. 14A of the Income Tax Act read with rule 8D deleted as tax free funds were more than investment made on which exempt income was earned.
ITAT Bangalore held that payment made by Google India Pvt. Ltd. to Google Ireland Limited (assessee) for sale of online advertisement space is not taxable in India as the same cannot be regarded as royalty or FTS.
Analysis of ITAT Delhi’s ruling: Sale of software products not taxable as royalty under India-Japan DTAA, citing Engineering Analysis case. Details of DCIT Vs Dassault Systems Biovia K.K.
ITAT Delhi held that expense towards management and marketing support service paid to foreign company is not taxable under Fee for Technical Service (FTS) under India-Netherlands Double Taxation Avoidance Agreement (DTAA) and hence TDS not deductible u/s. 195 of the Income Tax Act.
Discover the ITAT Delhi ruling on taxing income from providing business support services to Indian group entities. Analysis of Solvay Asia vs. DCIT case under India-Thailand DTAA.
CIT – International Taxation Vs. ESPN Star Sports Mauritius S.N.C ET Compagnie (Delhi High Court) The Delhi HC affirms the order of ITAT that ESPN Distribution does not constitute a PE in India and income earned from sports channel distribution cannot be taxed as royalty under provisions of the ITA read with India-Mauritius DTAA. Background […]
ITAT Mumbai held that the payment made towards interconnect usage charges to foreign telecom operators does not accrue or arise in India and in the absence of any permanent establishment in India could not be brought to tax in India under Article 7 of DTAA.
ITAT Delhi held that revenue received from various hotel owners for providing various centralized services cannot be treated as fees for included services (FIS) either under Article 12(4)(a) or 12(4)(b) of the India-US tax treaty. Thus, in absence of PE in India, the same is not taxable.
Debarghya Chattopadhaya vs DCIT – Kolkata ITAT rules taxpayer, possessing tax residency certificate and taxed in another contracting state, deserves treaty benefit u/s 90. Full analysis here.
HCG Global Communications Ltd. vs. DCIT (ITAT Bangalore) case ruling: Telecom interconnect usage payments received by a foreign company from an Indian operator deemed non-taxable as ‘royalty’ under the Income Tax Act.
