Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...
Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...
Income Tax : This guide explains how the abolition of DDT shifted the tax burden on dividends from companies to shareholders from 1 April 2020 ...
Income Tax : The guide explains how residents can avoid double taxation through DTAA benefits, Foreign Tax Credit, and Section 91 relief, outli...
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 : 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 : ITAT Delhi held legal services are not FTS under Section 9(1)(vii) and directed partner-wise DTAA examination. FTS addition was de...
Income Tax : ITAT Mumbai allowed deduction of ESOP expenses under Section 37(1) by following Karnataka High Court's ruling in Biocon Ltd. Tribu...
Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...
Income Tax : ITAT Pune held that Foreign Tax Credit cannot be denied merely because Form 67 was filed after the prescribed due date. The Tribun...
Income Tax : The Delhi ITAT ruled that no installation or supervisory PE existed in India as the activities did not exceed the 120-day threshol...
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...
Understand TDS obligations on payments to non-residents in India. Learn about Section 195 DTAA documentation and the consequences of non-compliance.
Denial of DTAA benefits to UAE resident over capital gains on debt mutual funds. The case examines whether ‘liable to tax’ requires actual tax payment.
ITAT Kolkata held that Foreign Tax Credit cannot be denied for delayed filing of Form No. 67 since the provision of DTAA override the provision of Section 90 of the Act and also filing it is directory requirement and not mandatory requirement. Accordingly, appeal allowed.
Supreme Court clarifies the scope of PE in India, ruling that Hyatt International’s operations are taxable under Indian law.
Addition made by AO in the hands of the trust was not justified as income from investments was taxable in the settlor’s hands and exempt under the India-UAE Double Taxation Avoidance Agreement (DTAA).
Delhi High Court confirms arbitral award for Fujitsu’s offshore supplies is business income, not taxable in India under Japan-India DTAA.
Learn how DTAAs affect capital gains tax on Indian mutual funds for non-residents. Judicial precedents clarify that gains are often only taxable in your country of residence.
Delhi ITAT rules India-Hong Kong DTAA exchange of information clause not retrospective, quashing assessments beyond limitation period in Sanjay Jain Vs DCIT case.
ITAT ruled DTAA exemption cannot be denied solely for non-availability of a Tax Residency Certificate (TRC). Circumstantial evidence can suffice, and DTAA prevails over domestic law.
Supreme Court held that Hyatt International has a fixed place Permanent Establishment in India within the meaning of Article 5(1) of the DTAA, and hence income received under Strategic Oversight Services Agreement [SOSA] attributable to such PE and is taxable in India.
