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Taxation in Digital Economy: Income Tax provisions in India vis-à-vis Permanent Establishment

Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...

July 13, 2024 546 Views 0 comment Print

Interpretation of Phrase “May be taxed” used in Paragraph 3 of Article 23 of India- UK DTAA, 1993

Income Tax : Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping...

June 7, 2024 786 Views 0 comment Print

Taxation for NRIs

Income Tax : Understanding taxation for NRIs: Learn about residential status, taxable income, deductions, and the importance of Double Taxation...

April 19, 2024 6216 Views 0 comment Print

Tax Avoidance and Inequality: Connecting the Dots in India

Income Tax : Explore the nexus between tax avoidance and inequality in India. Learn how legal loopholes deepen economic divides and discover st...

April 19, 2024 438 Views 0 comment Print

Payments made under distribution agreement not taxable in India: Delhi HC

Income Tax : CIT – International Taxation Vs. ESPN Star Sports Mauritius S.N.C ET Compagnie (Delhi High Court) The Delhi HC affirms the o...

March 23, 2024 1005 Views 0 comment Print


Latest News


Representation to Simplify & Automate TRC Issue Process for Indian Companies

Income Tax : Explore challenges in TRC applications under DTAA by Indian companies. KSCAA proposes reforms for a simpler, efficient process. Le...

June 22, 2024 198 Views 0 comment Print

India-Cyprus Double Tax Treaty: Benefits, Tax Recovery & Golden Passport

Income Tax : Explore the details of India's Double Tax Treaty with Cyprus, its signing date, benefits for both nations, tax recovery provisions...

December 11, 2023 702 Views 0 comment Print

Need for amendment of DTAA to stop double taxation of Indian IT firms

Income Tax : Need for early amendment of DTAA regulations to stop the double taxation of Indian IT firms: Ms. Anupriya Patel tells the visiting...

July 24, 2022 798 Views 0 comment Print

Cabinet approves Agreement with Saint Vincent for Tax Information exchange

Income Tax : The Union Cabinet, chaired by the Prime Minister Shri Narendra Modi has approved anAgreement between the Republic of India and Sa...

June 23, 2021 708 Views 0 comment Print

CBDT releases MLI synthesised text for India-Czechoslovak Socialist Republic tax treaty

Income Tax : CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modif...

March 19, 2020 369 Views 0 comment Print


Latest Judiciary


Filing Form 67 for Foreign Tax Credit is Directory, Not Mandatory: ITAT Indore

Income Tax : ITAT Indore rules in Asha Rani Pandya Vs DCIT/ACIT that filing Form 67 for claiming Foreign Tax Credit (FTC) is a directory requir...

July 15, 2024 432 Views 0 comment Print

Cricket Australia vs. ACIT: Live Transmission Fee Not Taxable as Royalty

Income Tax : Read the full text of the ITAT Delhi order on Cricket Australia vs. ACIT (International Taxation). Analysis includes why license f...

July 9, 2024 120 Views 0 comment Print

Income Taxable Under FTS Requires Direct Enablement or Skill Transfer, Advisory Services Not Sufficient Without PE Connection

Income Tax : For income to be taxable under FTS, there must be a direct enablement or transfer of skills or knowledge, which mere advisory or c...

July 8, 2024 267 Views 0 comment Print

Form 67 submission Not Mandatory for Availing  Foreign Tax Credit: ITAT Delhi

Income Tax : Read the full text of the ITAT Delhi order in Suchi Agrawal vs. ITO, where the requirement of Form-67 for foreign tax credit was d...

June 24, 2024 483 Views 0 comment Print

Delhi ITAT Rules No Tax on Technical Services to AE Without PE in India

Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...

June 20, 2024 447 Views 0 comment Print


Latest Notifications


CBDT Amends India-Spain Double Taxation Avoidance Agreement (DTAA)

Income Tax : Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and ch...

March 19, 2024 1989 Views 0 comment Print

CBDT notifies Tax Information Exchange Agreement: India-Samoa

Income Tax : Explore implications of Notification No. 21/2024 from Indias Ministry of Finance regarding the tax information exchange pact with ...

February 7, 2024 828 Views 0 comment Print

Income Tax Agreement Between India & Saint Vincent for information Exchange

Income Tax : Notification No. 96/2023-Income Tax: Learn about the agreement between India and Saint Vincent for tax information exchange and as...

November 1, 2023 594 Views 0 comment Print

DTAA between India and Chile notified by CBDT

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...

May 3, 2023 2298 Views 0 comment Print

Clarification on Most-Favoured-Nation clause in Protocol to India’s DTAAs

Income Tax : The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (part...

February 3, 2022 4191 Views 0 comment Print


Permanent Establishment in International Taxation

November 9, 2023 1296 Views 0 comment Print

Explore the intricacies of Permanent Establishment in international taxation, from UN Model to domestic laws. Learn about key provisions, tests, and recent developments. Contact us for clarity on International Taxation/DTAA.

Supreme Court’s Impact on India’s DTAA and MFN Provisions

November 8, 2023 1068 Views 0 comment Print

Explore the implications of the Indian Supreme Court’s recent judgment on Double Taxation Avoidance Agreements (DTAA) and Most Favored Nation (MFN) clauses, affecting European MNCs.

Canada Resident Eligible for India-Canada DTAA Benefit: ITAT Delhi

November 4, 2023 1839 Views 0 comment Print

ITAT Delhi rules in favor of a Canadian resident, allowing them to benefit from the India-Canada Double Taxation Avoidance Agreement (DTAA). Learn more in this article.

Comprehensive Guide: Tax Treatment of Dividends Received

November 3, 2023 7788 Views 0 comment Print

Explore dividend taxation for investors and corporations, including changes post-April 2020. Learn about domestic and foreign dividends, tax rates, and more.

Controversy surrounding Most Favoured Nation (‘MFN’) clause in DTAA

November 1, 2023 1770 Views 0 comment Print

Learn about the MFN (Most Favored Nation) Clause in Double Tax Avoidance Agreements, its recent controversy, and the Supreme Court’s clarification on its operation. Analysis and impact included.

Booking fee collected from non-resident airlines not taxable as royalty

November 1, 2023 564 Views 0 comment Print

ITAT Delhi held that the booking fee received by the assessee from non-resident airlines is taxable as ‘business income’ and not as ‘royalty’ u/s. 9(1)(vi) of the Income Tax Act and Article 13(3) of Indo-Spain DTAA.

Income Tax Agreement Between India & Saint Vincent for information Exchange

November 1, 2023 594 Views 0 comment Print

Notification No. 96/2023-Income Tax: Learn about the agreement between India and Saint Vincent for tax information exchange and assistance. Analysis & impact.

Sale of software not containing any element of service not fall under FTS

October 31, 2023 888 Views 0 comment Print

In the SoftwareONE Pte. Ltd. vs. ACIT case, the ITAT Delhi ruled that sales of software without any service component are not liable to be taxed as Fees for Technical Services (FTS) under the India-Singapore DTAA.

Relief under Section 90 and Form 67 in Indian Income Tax: A Guide and Consideration for Belated Filing

October 28, 2023 3168 Views 0 comment Print

Explore Indian Income Tax Section 90 & Form 67 for foreign tax relief. Learn about belated filing, rules, and ITAT judgments. Expert insights and guidance.

Double Taxation Relief: Rules and Benefits in India

October 27, 2023 16278 Views 0 comment Print

Double taxation can be a concern when a person residing in India earns income that is also taxable in a foreign country. To address this issue, individuals can claim credit for taxes paid outside India as Foreign Tax Credit (FTC)

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