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Circular No. 01/2025 outlines the application of the Principal Purpose Test (PPT) under India’s Double Taxation Avoidance Agreements (DTAAs) for treaty compliance.
In the event and income sourced in India was not characterized under the heads provided in the DTAA, the income would be taxable under the residual clause provided taxing right was allocated to source country in this case to India under the relevant DTAA.
Hire charges of a vessel did not constitute ‘Royalty’ as it was in the nature of business income and as there was no Permanent Establishment therefore, no taxability arose on account of business income.
Although Rule 128(9) requires Form 67, assessee’s compliance within this rule during the rectification stage demonstrated a good faith or effort to fulfil procedural requirement.
Switzerland suspends the MFN clause with India following a Supreme Court ruling in the Nestle case, impacting dividend tax rates for both countries.
Despite late filing of Form 67, assessee deserved the credit for taxes paid in Nepal since the provisions of DTAA (in this case DTAA with Nepal) had an overriding effect over other provisions of the Act.
Explore the tax implications for IPL players, including income tax for Indian and overseas players, TDS rates, and the role of DTAA agreements.
The assessee filed his return of Income on 27.08.2019. After filing the return, assessee received intimation u/s 143(1) of the Act dated 23.03.2021 and found that relief under section 90 of the Act had not been allowed amounting to Rs 73,658/-.
Delhi High Court held that the assessee was not afforded an opportunity to counter the allegation that it was a conduit company without any substance. Thus, the appeal filed by the revenue dismissed.
Delhi High Court held that provision of service by associated enterprise doesn’t include the element of ‘make available’ of technology to the assessee. Thus, benefit of Article 12 of India-USA DTAA available to such payment and hence TDS not deductible on the same.
