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Latest Articles


Countrywise Withholding Tax Rates: IT Act vs. Tax Treaties/DTAA

Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...

June 30, 2026 43609 Views 1 comment Print

Countrywise Withholding Tax Rates / Chart as per DTAA

Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...

June 30, 2026 455015 Views 28 comments Print

Comprehensive Guide: Tax Treatment of Dividends Received

Income Tax : This guide explains how the abolition of DDT shifted the tax burden on dividends from companies to shareholders from 1 April 2020 ...

June 10, 2026 23592 Views 1 comment Print

Double Taxation Relief: Rules and Benefits in India

Income Tax : The guide explains how residents can avoid double taxation through DTAA benefits, Foreign Tax Credit, and Section 91 relief, outli...

June 8, 2026 21237 Views 0 comment Print

Form 41 for DTAA Claims: Complete Guide under Income Tax Act 2025  

Income Tax : Form 41 is now compulsory for non-residents claiming DTAA benefits, replacing Form 10F. The update mandates online filing and ensu...

April 18, 2026 10491 Views 0 comment Print


Latest News


India–France DTAA Amended to Grant Source Country Taxing Rights on Share Capital Gains

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...

February 24, 2026 1440 Views 0 comment Print

CBDT Clarifies Guidance on Principal Purpose Test (PPT)

Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...

March 17, 2025 2793 Views 0 comment Print

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 906 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 1938 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 1059 Views 0 comment Print


Latest Judiciary


Section 9(1)(vii) FTS Addition Set Aside; Taxability Must Be Examined Under Relevant DTAA: ITAT Delhi

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...

July 5, 2026 405 Views 0 comment Print

ESOP Discount Allowed as Karnataka HC Precedent Covered Issue: ITAT Mumbai

Income Tax : ITAT Mumbai allowed deduction of ESOP expenses under Section 37(1) by following Karnataka High Court's ruling in Biocon Ltd. Tribu...

June 25, 2026 150 Views 0 comment Print

Excess Royalty Refunded Under APA Cannot Be Taxed as Only Retained Amount Is Taxable: Bombay HC

Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...

June 20, 2026 114 Views 0 comment Print

Foreign Tax Credit Cannot Be Denied Merely for Delay in Filing Form 67: ITAT Pune

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...

June 13, 2026 90 Views 0 comment Print

No Fixed Place PE in India as Customer Premises Were Not at Foreign Company’s Disposal: ITAT Delhi

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...

June 13, 2026 213 Views 0 comment Print


Latest Notifications


CBDT Notifies India-Japan Tax Recovery Pact

Income Tax : The government enforced a tax collection assistance agreement with Japan effective from 8 July 2025. The notification enables cros...

April 2, 2026 981 Views 0 comment Print

CBDT notifies amended India-Brazil Tax Treaty

Income Tax : The amendment expands the definition of permanent establishment to include service-based activities exceeding 183 days. It clarifi...

March 30, 2026 825 Views 0 comment Print

India Enforces Amended DTAA with Belgium from June 2025 to Curb Tax Evasion

Income Tax : The Finance Ministry notifies the India-Belgium protocol amending the 1993 tax treaty, effective June 26, 2025, updating definitio...

November 10, 2025 1269 Views 0 comment Print

India–Qatar DTAA & Protocol Notified by CBDT

Income Tax : Notification implements the India-Qatar Double Taxation Avoidance Agreement (DTAA) and Protocol, effective from the next fiscal ye...

October 24, 2025 1797 Views 0 comment Print

Guidance on Principal Purpose Test (PPT) in India’s DTAAs

Income Tax : Circular No. 01/2025 outlines the application of the Principal Purpose Test (PPT) under India's Double Taxation Avoidance Agreemen...

January 21, 2025 5742 Views 0 comment Print


Income from non-domain services not taxable as FTS/FIS under India-USA DTAA

May 15, 2025 1404 Views 0 comment Print

ITAT Delhi rules GoDaddy’s income from domain registration and web services is not taxable as royalty or FTS/FIS, citing judicial precedents.

Section 44C Inapplicable to Exclusive Head Office Expenses for Indian Branches Abroad

May 12, 2025 870 Views 0 comment Print

ITAT Mumbai held that head office expenditure incurred outside India exclusively for the Indian branches does not fall within the ambit of section 44C of the Income Tax Act. Accordingly, appeal of the assessee allowed.

Hotel Reimbursement of Marketing & Other Fees Not Fee for Technical Services

May 9, 2025 957 Views 0 comment Print

Reimbursement of expenses qua marketing fees, frequent flyer programme, frequent guest programme and reservation fees received by assessee cannot be treated as fee for technical services: HC

Bandwidth Charges Not Royalty Under Income Tax Act: Delhi HC

May 9, 2025 1116 Views 0 comment Print

Delhi High Court dismisses revenue appeal against Bharti Airtel, reaffirming that charges paid for bandwidth to overseas operators are not taxable as royalty under the Income Tax Act.

Hotel Services Fee Not Taxable as Technical Fees: Delhi HC

May 9, 2025 1002 Views 0 comment Print

Delhi High Court rules payments for hotel centralised services like marketing and reservations are not taxable as technical fees, citing prior judgment.

India-UK FTA : A Strategic Leap Towards Viksit Bharat 2047

May 7, 2025 912 Views 0 comment Print

On May 6, 2025, India and the United Kingdom officially concluded a comprehensive Free Trade Agreement (FTA), marking a significant advancement in bilateral economic relations.

Subscription fees for e-magazine doesn’t partake character of Fee for Technical Service

May 5, 2025 999 Views 0 comment Print

The present appeal has been preferred by the revenue. The controversy involved in the present appeals pertains to the treatment of “commission income” and the amounts received by the Assessee as “subscription fee”.

Intra-Group Services Not Taxable in India as They Fall Outside FTS Scope: ITAT Delhi

April 29, 2025 951 Views 0 comment Print

ITAT Delhi held that services rendered under Intra Group Service Agreement do not make available technical knowledge and hence would not fall within the definition of FTS as provided under Article 13(4) of India UK DTAA and hence not taxable in India.

Interest Payments to CDB Exempt under Article 11(3) of India-China DTAA

April 29, 2025 516 Views 0 comment Print

ITAT Delhi dismisses Revenue’s appeal against Tata Teleservices on taxability of interest paid to China Development Bank under India-China DTAA Article 11(3).

Disallowance u/s. 40(a)(i) for non-deduction of TDS from foreign remittance restored back to AO

April 24, 2025 2025 Views 0 comment Print

The assessee is carrying on business activity of export of software development and distinct services as Proprietor of Versatiletech. The return was picked up for scrutiny for the reason of compliance with TDS provisions and also foreign outward remittances.

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