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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 4689 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 210 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 780 Views 0 comment Print

Key Provisions and Implications of India-USA Tax Treaty

Income Tax : Explore the India-USA Tax Treaty, its provisions, implications, and how it prevents double taxation. Learn about residency, taxati...

March 18, 2024 1542 Views 1 comment Print

Foreign Tax Credit (FTC): Importance, Concept and How to Claim FTC

Income Tax : Understanding Foreign Tax Credit (FTC) in India: Learn its significance, rules, claiming procedure, case law insights, and steps t...

March 18, 2024 1014 Views 0 comment Print


Latest News


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 528 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 774 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 687 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 342 Views 0 comment Print

CBDT releases MLI synthesised text for India-Poland tax treaty

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

March 19, 2020 639 Views 0 comment Print


Latest Judiciary


ITAT Ruling on Taxability of FTS, in absence of specific clause in DTAA

Income Tax : Learn about the tax dispute between Diamond Manufacturing Management and the Indian Revenue Authority, involving fees for technica...

April 21, 2024 423 Views 0 comment Print

Disallowance u/s 14A deleted as interest free own funds exceeded investment: ITAT Mumbai

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 ...

April 5, 2024 474 Views 0 comment Print

Sale of Online Advertisement Space Not Taxable as Royalty or FTS in India: ITAT Bangalore

Income Tax : ITAT Bangalore held that payment made by Google India Pvt. Ltd. to Google Ireland Limited (assessee) for sale of online advertisem...

April 2, 2024 336 Views 0 comment Print

Software Sales Not Royalty Income under India-Japan DTAA: ITAT Delhi

Income Tax : Analysis of ITAT Delhi's ruling: Sale of software products not taxable as royalty under India-Japan DTAA, citing Engineering Analy...

March 27, 2024 216 Views 0 comment Print

TDS u/s. 195 not deductible on expense of management and marketing support service paid to foreign company: ITAT Delhi

Income Tax : ITAT Delhi held that expense towards management and marketing support service paid to foreign company is not taxable under Fee for...

March 27, 2024 561 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 921 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 699 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 567 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 1866 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 3945 Views 0 comment Print


Indian subsidiary operating in independent manner doesn’t constitute PE

October 4, 2023 843 Views 0 comment Print

ITAT Mumbai held that the Indian Subsidiary operating in an independent manner doesn’t constitute as a “Permanent Establishment” in India and hence income of the assessee is not allowable to be taxed in India.

Subscription, professional and training services doesn’t qualify as FTS under India-Netherland DTAA

October 2, 2023 1095 Views 0 comment Print

ITAT Delhi held that income from subscription, professional and training services for use of software doesn’t fall within the definition of Fees for Technical Services (FTS) under India-Netherlands DTAA and hence cannot be taxed in India.

Consultancy service involving substantial technical skill cannot be treated as FIS

September 30, 2023 912 Views 0 comment Print

ITAT Delhi held that as per India-USA DTAA provision of consultancy services cannot be treated as FIS merely because the service provider while providing consultancy services had used substantial technical skill and expertise.

Broadcasting Reproduction Right not covered under definition of Royalty under Article 12 of India-USA DTAA

September 30, 2023 381 Views 0 comment Print

ITAT Mumbai held that Broadcasting Reproduction Right is not covered under the definition of Royalty under the Income Tax Act as well as Article 12 of the India-USA DTAA.

Dividend received by company having PE in Oman is not taxable in India

September 30, 2023 642 Views 0 comment Print

Supreme Court held that dividend received by the Indian company having permanent establishment in Oman is not taxable in India in terms of Article 25 read with Article 8 (bis) of the Omani Tax Laws

Consideration paid for testing ability of candidates doesn’t qualify as royalty hence TDS not deductible

September 29, 2023 321 Views 0 comment Print

ITAT Delhi held that consideration paid for testing the ability of candidates do not fall within the purview of royalty under Article 13 of India-UK DTAA. Hence, there is no obligation withholding of tax u/s 195 of the Income Tax Act.

Salary not taxable in India in terms of Article 15(1) of India-Netherland DTAA

September 27, 2023 894 Views 0 comment Print

ITAT Delhi held that salary income not taxable in India both u/s. 9(1) as services are rendered outside India and also not taxable under Article 15(1) of India-Netherland DTAA as required conditions satisfied.

Purchase of own shares comes within the ambit of dividend u/s 2(22) of Income Tax Act

September 21, 2023 1935 Views 0 comment Print

ITAT Chennai held that transaction of purchase of own shares by the appellant company is distribution of accumulated profits within the meaning of section 2(22) of the Income Tax Act, 1961. Accordingly, it is treated as dividend u/s. 2(22)(a)/2(22)(d) read with section 115-O of the Act.

AWS India liable to withhold 8% tax of remittance on account of reseller fee paid to AWS USA

September 18, 2023 864 Views 0 comment Print

Delhi High Court held that Amazon Web Services India Pvt. Ltd. (AWS India) is liable to withhold 8% (instead of 16%) tax of remittance on account of reseller fee paid to AWS USA.

Taxation of Salary for Work in Foreign Jurisdiction Under India-China DTAA

September 14, 2023 537 Views 0 comment Print

An in-depth analysis of the Ramesh Kumar AE Vs ITO (ITAT Chennai) case. Discover why the ITAT Chennai ruled that salary earned in a foreign jurisdiction is not taxable in India.