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...
It also referred to similar findings in Matrix Partners India Investment Holdings, LLC vs DCIT and other precedents, reinforcing that exempt income did not form part of the computation of total income under Indian law.
ITAT Delhi rules Crocs Inc.’s service income not taxable in India under DTAA, as services did not “make available” technical knowledge to Crocs India.
ITAT Mumbai rules Sita USA’s airline software services not taxable in India under FTS or DTAA. Revenue appeals for AY 2014-15 to 2021-22 dismissed.
ITAT Mumbai rules on Anushka Shah vs ITO case, addressing capital gains taxability on mutual fund units under the India-Singapore DTAA.
ITAT Mumbai allows tax exemption on capital gains for NRI under India-Singapore DTAA, rejecting AO’s classification of mutual fund units as taxable shares.
ITAT Kolkata ruled that filing Form 67 for Foreign Tax Credit (FTC) under DTAA is procedural, not mandatory. Read key takeaways from Timirbaran Mazumder vs. DCIT.
Article explores effectiveness and influence of Bilateral Investment Treaties (BITs) on FDI flows with particular emphasis within Indian context but referring to general international experiences.
CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not affect other tax provisions.
ITAT Bangalore held that addition under section 28(iv) of the Income Tax Act for receiving fixed assets from sister concern on free of cost basis unjustified as no benefit is derived from the same. Accordingly, order of CIT(A) upheld and appeal of revenue dismissed.
Switzerland halts the unilateral application of the MFN clause under its tax treaty with India from 2025, following the Indian Supreme Court’s 2023 ruling.
