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DTAA

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Essential Financial Steps and Tax Tips that every NRI’s must not miss

Finance : Discover essential financial steps and tax tips for NRIs, including converting accounts, trading restrictions, and leveraging DTAA...

July 18, 2024 717 Views 0 comment Print

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 660 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 882 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 6678 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 483 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 234 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 759 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 816 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 717 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 390 Views 0 comment Print


Latest Judiciary


Condition of ‘make available’ not satisfied hence technical service not taxable: ITAT Delhi

Income Tax : ITAT Delhi held that the condition of make available was not satisfied for services when provided by assessee did not enabled the ...

August 16, 2024 72 Views 0 comment Print

Domestic company paying DDT u/s. 115O doesn’t enter domain of DTAA: ITAT Pune

Income Tax : ITAT Pune held that the DTAA does not get triggered at all when a domestic company pays DDT u/s. 115O of the Income Tax Act. In nu...

August 16, 2024 78 Views 0 comment Print

Reassessment unsustained as based on entirely new reason which deprives assessee’s right to object: Delhi HC

Income Tax : Delhi High Court held that initiation of reassessment based on entirely new or previously undisclosed material or reasoning depriv...

August 12, 2024 192 Views 0 comment Print

No tax on amount paid for certification services rendered by foreign entities in absence of fixed place of business in India

Income Tax : Understand the Ahmedabad ITAT ruling that payments for certification services by foreign entities are not taxable in India without...

August 1, 2024 162 Views 0 comment Print

Additional grounds raised in appeal needs adjudication by lower authority: ITAT Chennai

Income Tax : ITAT Chennai restored the matter back to the file of AO for re-adjudication as additional ground raised by the assessee in appeal ...

July 26, 2024 654 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 2238 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 867 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 609 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 2403 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 4248 Views 0 comment Print


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

September 30, 2023 468 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 732 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 339 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 1221 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 2505 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 1041 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 648 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.

Double Taxation: What to Do If You’re Taxed in Two Countries on Same Income

September 11, 2023 2277 Views 0 comment Print

Confused about being taxed in two countries on same income? Learn how Double Taxation Avoidance Agreements (DTAA) and Foreign Tax Credit (FTC) can help you navigate this complex issue.

Payment towards interconnectivity utility charges from Indian customers not taxable as Royalty

September 9, 2023 909 Views 0 comment Print

ITAT Bangalore held that payments received towards interconnectivity utility charges from Indian customers / end users cannot be considered as Royalty to be brought to tax in India under section 9(1)(vi) of the Income Tax Act and also as per DTAA.

Gain from sale of equity shares is exempt under Article 13(4) of India-Mauritius DTAA

September 9, 2023 843 Views 0 comment Print

ITAT Delhi held that as shares were acquired prior to 01.04.2017, gain derived from sale of such equity shares is exempt under Article 13(4) of India-Mauritius DTAA.

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