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...
Karnataka High Court held that TDS is not deductible on payment to non-residents for advertisements in several social medias like Facebook, Amazon Web Services and Rocket Science Group. Accordingly, appeals are dismissed.
ITAT Mumbai held that that reimbursement of expenses at cost is not taxable as fees for technical services since there is no element of income attached to the transaction. Accordingly, revenue’s appeal dismissed.
Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidiary of Adobe Software Trading Company Limited and Adobe Systems Incorporated is the ultimate parent company of ADIR.
ITAT Delhi rules IT support payments to CPP UK not taxable as fees for technical services due to failure of ‘make available’ test under India-UK DTAA.
Learn how international transactions are taxed under India’s Income Tax Act, including DTAAs, transfer pricing, TDS provisions, and compliance essentials.
ITAT Mumbai ruled on TVF Fund Ltd’s appeal regarding tax loss set-off under DTAA. Key issues include carry-forward losses, taxability, and judicial precedents.
ITAT Bangalore upheld CIT(A)’s decision, ruling that interconnect charges paid to A1 Telekom Austria are not taxable as royalty under the Income Tax Act or DTAA.
ITAT Delhi held that advertisement and distribution revenue earned by Discovery Asia Inc. is taxable as per Mutual Agreement Resolution (MAP) as decided by competent authority of India & USA. Accordingly, appeal allowed partially.
ITAT Chennai held that payments are in the nature of selling commission to foreign agents who is not having permanent establishment or business connection in India is not taxable in India and accordingly, TDS u/s. 195 not deductible.
Circular No. 01/2025 outlines the application of the Principal Purpose Test (PPT) under India’s Double Taxation Avoidance Agreements (DTAAs) for treaty compliance.
