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...
ITAT Delhi held that apportionment of license fees as 10% towards recorded events and 90% towards live coverage instead of 5% and 95% as claimed by sports broadcasters. Accordingly, appeal partly allowed.
Delhi ITAT upholds non-taxability of Converteam Group’s support services, affirming “make available” clause applicability via MFN protocol in India-France DTAA.
The Tribunal therefore, has rightly affirmed the conclusion arrived at by CIT(Appeals) in deleting the tax demand relatable to difference between 20% and the actual tax rate on which tax was deducted by the respondent assessee in terms of the relevant DTAAS.
AO treated this amount as fees for technical services (FTS) taxable in India, and Dispute Resolution Panel (DRP) upheld the assessment. DRP looked into whether the payment made by an Indian company, FSTI, to Ethiopian Airlines (EA) was taxable in India as FTS.
Delhi High Court held that the benefit of exclusion of time by virtue of Explanation (ix) of Section 153B of the Income Tax Act cannot be available here as reference made for information under Indo-Swiss DTAA was invalid. Accordingly, questions to law as framed are answered against the Revenue.
AO however, held that STCG on the sale of rights entitlement was to be taxed as “sale of shares” under Article 13(5) of the India-Ireland DTAA, making an addition towards STCG as taxable in India.
ITAT Kolkata held that filing of Form No. 67 is directory and no mandatory and the credit for foreign taxes cannot be denied for mere delay in filing the Form No. 67. Accordingly, appeal of the assessee allowed.
In today’s interconnected world, global trade and cross-border investments are the backbone of economic growth. No nation remains entirely self-reliant—countries rely on imports, exports, and foreign capital to drive their economies. However, this interdependence has led to complex tax issues, particularly double taxation, where the same income is taxed in more than one country. To […]
Delhi High Court upholds ITAT ruling: Cloud service subscription payments to foreign firms are not taxable as royalty under DTAA or Income Tax Act.
Delhi High Court dismisses appeals, reiterating Supreme Court ruling that payments for software use/resale are not royalties under Indian tax law. No TDS liability.
