Income Tax : Form 41 is now compulsory for non-residents claiming DTAA benefits, replacing Form 10F. The update mandates online filing and ensu...
Income Tax : The Court held that indirect share transfers deriving value from Indian assets are taxable. Treaty benefits were denied due to tax...
Income Tax : Income Tax Department Ministry of Finance, Government of India DTAA & FTC Double Taxation Avoidance Agreement (DTAA) & For...
Income Tax : The case explains the statutory framework governing appeals and revisions under the Income-tax Act. It highlights the role of face...
Income Tax : The article explains how ESOP taxation spans salary, capital gains, DTAA, and disclosure requirements. It highlights that errors i...
Income Tax : India and France have signed a protocol granting full taxing rights on capital gains from share sales to the country of company re...
Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...
Income Tax : Explore challenges in TRC applications under DTAA by Indian companies. KSCAA proposes reforms for a simpler, efficient process. Le...
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 Delhi ITAT held that belated filing of Form No. 67 is only a procedural lapse and cannot extinguish substantive Foreign Tax Cr...
Income Tax : The Supreme Court affirmed that payments for cloud computing services are not royalty where no intellectual property rights are tr...
Income Tax : The Tribunal set aside the dismissal of a delayed appeal, holding that the issue of distribution fee taxability requires fresh exa...
Income Tax : The Tribunal held that consultancy payments for architectural services were not FTS since no technical knowledge was made availabl...
Income Tax : The tribunal held that gains from sale of shares did not fall under Article 14(4). It ruled that Article 14(6) applies, making gai...
Income Tax : The government enforced a tax collection assistance agreement with Japan effective from 8 July 2025. The notification enables cros...
Income Tax : The amendment expands the definition of permanent establishment to include service-based activities exceeding 183 days. It clarifi...
Income Tax : The Finance Ministry notifies the India-Belgium protocol amending the 1993 tax treaty, effective June 26, 2025, updating definitio...
Income Tax : Notification implements the India-Qatar Double Taxation Avoidance Agreement (DTAA) and Protocol, effective from the next fiscal ye...
Income Tax : Circular No. 01/2025 outlines the application of the Principal Purpose Test (PPT) under India's Double Taxation Avoidance Agreemen...
The ITAT Chennai ruled that an Indian employee’s salary for services rendered in the US is not taxable in India, upholding the India-US DTAA and clarifying that the place of service, not receipt, determines taxability.
The ITAT Mumbai has ruled that Delta Air Lines’ income from code-sharing agreements with third-party carriers is exempt from tax in India under Article 8 of the India-USA DTAA, as it qualifies as “profits from the operation of aircrafts in international traffic.”
A summary of India’s Double Taxation Avoidance Agreements (DTAAs), covering the legal framework, methods of relief, and rules for international tax compliance.
The Karnataka High Court dismissed an appeal by the Income Tax Department, ruling that payments to Syna Media for software licenses are not taxable as royalty, citing the Supreme Court’s precedent in the Engineering Analysis case.
In a key ruling, the ITAT upholds that fees for accessing a copyrighted database are not royalty under Indian tax law or the India-UK DTAA, affirming no taxable presence for the UK company.
Delhi High Court rules purchases from foreign AEs without a PE are not taxable in India, preventing Section 40(a)(i) disallowance and upholding DTAA non-discrimination clauses.
DTAAs prevent double taxation, support cross-border trade, and provide clarity for individuals and businesses operating internationally.
An ITAT Pune ruling confirms that domestic companies cannot use DTAAs to reduce Dividend Distribution Tax (DDT) under Section 115-O, as the tax is a levy on the company, not the shareholder.
ITAT Mumbai rules against a Section 263 revision order, stating the Assessing Officer had conducted sufficient inquiry in the original assessment.
The Karnataka High Court rules free prototypes from AEs are not taxable under Section 28(iv), and payments for general employee training are not taxable as FTS under the India-Singapore DTAA.
