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...
Significant to note that the assessment order was passed in the backdrop of information received from the French Government under the Double Taxation Avoidance Agreement (DTAA), indicating that assessee held bank accounts in HSBC Private Bank (Suisse), SA, Switzerland.
Gujarat High Court held that since provisions of DTAA would override the provisions of the Domestic Act where the provisions of the DTAA are more beneficial to the assessee. Thus, section 206AA of the Income Tax Act doesn’t override the provisions of 90(2) of the Income Tax Act.
Understand tax implications for Indian residents with income from countries without DTAA, including capital gains, rental income, and foreign tax relief.
Delhi High Court held that payments received for services that may require technical expertise, technical inventions or technology would not qualify as Fees for Technical Services under Article 13 of the India-UK DTAA. Accordingly, appeal allowed.
Learn how non-residents can avail beneficial tax rates under DTAA when receiving Indian income, based on Section 90(2) and key judicial precedents.
Assessee is a foreign company and a tax resident of Mauritius. The assessee is carrying on investment activity in India by way of investments in shares and debentures of Indian companies through recognized stock exchanges in India.
ITAT Hyderabad held that denial of credit for Foreign Tax Credit merely due to delay in filing of Form 67 not justified as Form 67, although belatedly, was filed before the AO passed order u/s 143(3) of the Act. Accordingly, appeal allowed.
ITAT Delhi held that income earned by GoDaddy.com from providing domain name registration services to Indian Customers is not taxable in India. Further, income from provision of non-domain service fall outside ambit of Fee for Technical Services and hence not taxable.
Understand the taxability of royalty income for German companies in India, DTAA applicability, and the procedure for claiming tax credits for TDS paid in India against German tax obligations.
ITAT Mumbai clarifies derivative income taxability for Mauritius fund. Rules derivatives are distinct from shares, exempting gains from Indian tax under India-Mauritius DTAA Article 13(4).
