Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...
Income Tax : Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping...
Income Tax : Understanding taxation for NRIs: Learn about residential status, taxable income, deductions, and the importance of Double Taxation...
Income Tax : Explore the nexus between tax avoidance and inequality in India. Learn how legal loopholes deepen economic divides and discover st...
Income Tax : CIT – International Taxation Vs. ESPN Star Sports Mauritius S.N.C ET Compagnie (Delhi High Court) The Delhi HC affirms the o...
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 Union Cabinet, chaired by the Prime Minister Shri Narendra Modi has approved anAgreement between the Republic of India and Sa...
Income Tax : CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modif...
Income Tax : ITAT Indore rules in Asha Rani Pandya Vs DCIT/ACIT that filing Form 67 for claiming Foreign Tax Credit (FTC) is a directory requir...
Income Tax : Read the full text of the ITAT Delhi order on Cricket Australia vs. ACIT (International Taxation). Analysis includes why license f...
Income Tax : For income to be taxable under FTS, there must be a direct enablement or transfer of skills or knowledge, which mere advisory or c...
Income Tax : Read the full text of the ITAT Delhi order in Suchi Agrawal vs. ITO, where the requirement of Form-67 for foreign tax credit was d...
Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...
Income Tax : Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and ch...
Income Tax : Explore implications of Notification No. 21/2024 from Indias Ministry of Finance regarding the tax information exchange pact with ...
Income Tax : Notification No. 96/2023-Income Tax: Learn about the agreement between India and Saint Vincent for tax information exchange and as...
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...
Income Tax : The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (part...
Bombay High Court held that certificates issued by the Singapore Tax Authorities certifying that capital gain income would be brought to tax in Singapore is sufficient evidence for accepting the legal position.
In present facts of the case, the Hon’ble Tribunal held that expenses made pertaining to Club Membership fees shall be allowed as business expenditure.
ITAT Chennai held that payment of rental or ocean freight for ships is covered by Article 8 of India-Korea DTAA. Accordingly, the assessee is not liable to deduct TDS and therefore, disallowance invoking provisions of section 40(a)(i) of the Income Tax Act unsustainable.
ITAT Delhi held that as per Article 8 of India–Singapore DTAA receipts from operation of ships and aircrafts in international traffic is taxable in the country of residence of the recipient. Therefore, amounts received by the assessee from operation of ships in international traffic would be exempt.
ITAT Bangalore held that delay in filing the return and Form No.67, beyond period under section 139(1) of the Act, is not fatal to the claim of FTC. Foreign Tax Credit duly available in respect of income taxable in India and received outside India for the amount of taxes paid outside India.
ITAT Mumbai held that the assessee has merely got the license to use the software for its daily business requirement and has never owned the same. Further, such expense was used for business purpose on yearly rent basis it has not given any enduring benefit. Hence, such expense are revenue in nature.
ITAT Delhi held that amount received from its Indian subsidiary towards IT and SAP charges cannot be treated as Fees for Technical Services (FTS) under Article 12(4)(a) of India – Portugal DTAA. Accordingly, additions unsustainable.
ITAT Delhi held that the receipts from centralised service income are not taxable as Fees for Technical Services (FTS)/ Fees for included Services (FIS) under Article 12(4)(a) of India-USA DTAA.
Explore the key aspects and implications of the case Avaya International Sales Ltd Vs ACIT, wherein ITAT Delhi directed a fresh examination of the taxability of support/maintenance services under the India-Ireland DTAA.
A detailed analysis of the decision made by the Income Tax Appellate Tribunal (ITAT) Mumbai in the case of Ambuja Cements Limited Vs ACIT. The Tribunal allowed rectification of a mistake apparent from the record under section 254(2) of the Income Tax Act, 1961
