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Taxation for NRIs

Income Tax : Understanding taxation for NRIs: Learn about residential status, taxable income, deductions, and the importance of Double Taxation...

April 19, 2024 5340 Views 0 comment Print

Tax Avoidance and Inequality: Connecting the Dots in India

Income Tax : Explore the nexus between tax avoidance and inequality in India. Learn how legal loopholes deepen economic divides and discover st...

April 19, 2024 318 Views 0 comment Print

Payments made under distribution agreement not taxable in India: Delhi HC

Income Tax : CIT – International Taxation Vs. ESPN Star Sports Mauritius S.N.C ET Compagnie (Delhi High Court) The Delhi HC affirms the o...

March 23, 2024 858 Views 0 comment Print

Key Provisions and Implications of India-USA Tax Treaty

Income Tax : Explore the India-USA Tax Treaty, its provisions, implications, and how it prevents double taxation. Learn about residency, taxati...

March 18, 2024 2211 Views 1 comment Print

Foreign Tax Credit (FTC): Importance, Concept and How to Claim FTC

Income Tax : Understanding Foreign Tax Credit (FTC) in India: Learn its significance, rules, claiming procedure, case law insights, and steps t...

March 18, 2024 1191 Views 0 comment Print


Latest News


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 558 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 783 Views 0 comment Print

Cabinet approves Agreement with Saint Vincent for Tax Information exchange

Income Tax : The Union Cabinet, chaired by the Prime Minister Shri Narendra Modi has approved anAgreement between the Republic of India and Sa...

June 23, 2021 696 Views 0 comment Print

CBDT releases MLI synthesised text for India-Czechoslovak Socialist Republic tax treaty

Income Tax : CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modif...

March 19, 2020 348 Views 0 comment Print

CBDT releases MLI synthesised text for India-Poland tax treaty

Income Tax : CBDT has released the synthesised text for India-Poland tax treaty. It represents their shared understanding of the modifications ...

March 19, 2020 648 Views 0 comment Print


Latest Judiciary


IT Support Payments Not FTS under Article 12 of India-Netherlands DTAA

Income Tax : In a landmark ruling, ITAT Mumbai provides relief to Shell IT, asserting that payments for IT support aren't considered FTS under ...

May 18, 2024 234 Views 0 comment Print

Amount received towards Interconnectivity Utility charges from Indian Customers was not taxable as Royalty

Income Tax : Assessee was incorporated in Japan and was in the business of providing telecommunication services. Assessee provided fixed, mobil...

May 6, 2024 324 Views 0 comment Print

ITAT Ruling on Taxability of FTS, in absence of specific clause in DTAA

Income Tax : Learn about the tax dispute between Diamond Manufacturing Management and the Indian Revenue Authority, involving fees for technica...

April 21, 2024 600 Views 0 comment Print

Disallowance u/s 14A deleted as interest free own funds exceeded investment: ITAT Mumbai

Income Tax : ITAT Mumbai held that disallowance made u/s. 14A of the Income Tax Act read with rule 8D deleted as tax free funds were more than ...

April 5, 2024 507 Views 0 comment Print

Sale of Online Advertisement Space Not Taxable as Royalty or FTS in India: ITAT Bangalore

Income Tax : ITAT Bangalore held that payment made by Google India Pvt. Ltd. to Google Ireland Limited (assessee) for sale of online advertisem...

April 2, 2024 402 Views 0 comment Print


Latest Notifications


CBDT Amends India-Spain Double Taxation Avoidance Agreement (DTAA)

Income Tax : Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and ch...

March 19, 2024 1287 Views 0 comment Print

CBDT notifies Tax Information Exchange Agreement: India-Samoa

Income Tax : Explore implications of Notification No. 21/2024 from Indias Ministry of Finance regarding the tax information exchange pact with ...

February 7, 2024 753 Views 0 comment Print

Income Tax Agreement Between India & Saint Vincent for information Exchange

Income Tax : Notification No. 96/2023-Income Tax: Learn about the agreement between India and Saint Vincent for tax information exchange and as...

November 1, 2023 579 Views 0 comment Print

DTAA between India and Chile notified by CBDT

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...

May 3, 2023 1983 Views 0 comment Print

Clarification on Most-Favoured-Nation clause in Protocol to India’s DTAAs

Income Tax : The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (part...

February 3, 2022 4050 Views 0 comment Print


Brief understanding of Article 1 ‘Persons Covered’ of UN Model

March 9, 2023 804 Views 0 comment Print

Article 1 of United Nations Model Convention on Income and Capital (the Model) provides scope and application of Convention. It outlines the persons and entities to which the Model applies, as well as the types of taxes to which it is applicable.

Payment by GIPL to Google US towards seconded employees is outside purview of FTS/ FIS

March 4, 2023 1608 Views 0 comment Print

ITAT Bangalore held that the amount paid by Google India Private Limited (GIPL) to M/s. Google LLC (US) towards seconded employees doesn’t come under the purview of FTS (Fees for Technical Services) or FIS (Fees for Included Services) under the Income Tax Act or under DTAA.

TDS to be deducted as per Tax Treaties rates even when PAN of non-resident payee not available

February 27, 2023 6672 Views 0 comment Print

ITAT Ahmedabad held that in case of payments to non-resident, when PAN of non-resident payee is not available, TDS is to be deducted at the rates applicable in respective Tax Treaties.

Non-inclusion of interest income for misplace of fixed deposit is illogical argument

February 27, 2023 879 Views 0 comment Print

ITAT Delhi held that addition of interest income on fixed deposit with Canara Bank sustainable as contention of the assessee that fixed deposit is misplaced and hence there is no question of earning any interest income is illogical.

Interest paid by Indian Branch to Head office is not taxable in India in terms of India-France DTAA

February 27, 2023 1275 Views 0 comment Print

ITAT Mumbai held that that the interest paid by the Indian branch-PE to the head office-GE is not taxable in India in terms of India-France DTAA.

Sale of software not taxable in terms of India-Ireland DTAA

February 16, 2023 714 Views 0 comment Print

ITAT Kolkata held that sale of software is transfer of ‘copyrighted article’ and not transfer of any ‘copyright’ and hence cannot be characterized as ‘Royalty’. Hence, the same is not taxable in terms of India-Ireland DTAA.

Capital gain earned on sale of share not taxable in India in terms of India-Singapore DTAA

February 14, 2023 3702 Views 0 comment Print

Delhi High Court held that capital gain earned on sale of shares by non-resident is not taxable in terms of Article 13(4) of India and Singapore (DTAA) based on Tax Residency Certificate. Also held that revenue has to accept Tax Residency Certificate and cannot go behind it.

Centralized services fees cannot be treated as Fee for Technical Services and hence not taxable

February 9, 2023 972 Views 0 comment Print

ITAT Delhi held that the centralised services fee received by the assessee cannot be treated as FTS under Article 12 of the India-Singapore tax treaty, hence not taxable in India.

Reasons to Form an Offshore Company This Year

February 1, 2023 1080 Views 0 comment Print

Companies register offshore for a variety of reasons, including tax benefits and financial privacy. Whether you need a company abroad depends on your specific business needs and goals.

Mere passing off project specific architectural, drawings and design not taxable as Fee for Technical Services

January 31, 2023 1041 Views 0 comment Print

ITAT Mumbai held that mere passing off project specific architectural, drawings and designs with measurements does not amount to making available technical knowledge, experience, skill, knowhow or processes. Accordingly, cannot be brought to tax as Fee for Technical Services.

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