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Taxation in Digital Economy: Income Tax provisions in India vis-à-vis Permanent Establishment

Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...

July 13, 2024 546 Views 0 comment Print

Interpretation of Phrase “May be taxed” used in Paragraph 3 of Article 23 of India- UK DTAA, 1993

Income Tax : Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping...

June 7, 2024 786 Views 0 comment Print

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 6216 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 438 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 1005 Views 0 comment Print


Latest News


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 198 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 702 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 798 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 708 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 369 Views 0 comment Print


Latest Judiciary


Filing Form 67 for Foreign Tax Credit is Directory, Not Mandatory: ITAT Indore

Income Tax : ITAT Indore rules in Asha Rani Pandya Vs DCIT/ACIT that filing Form 67 for claiming Foreign Tax Credit (FTC) is a directory requir...

July 15, 2024 432 Views 0 comment Print

Cricket Australia vs. ACIT: Live Transmission Fee Not Taxable as Royalty

Income Tax : Read the full text of the ITAT Delhi order on Cricket Australia vs. ACIT (International Taxation). Analysis includes why license f...

July 9, 2024 120 Views 0 comment Print

Income Taxable Under FTS Requires Direct Enablement or Skill Transfer, Advisory Services Not Sufficient Without PE Connection

Income Tax : For income to be taxable under FTS, there must be a direct enablement or transfer of skills or knowledge, which mere advisory or c...

July 8, 2024 267 Views 0 comment Print

Form 67 submission Not Mandatory for Availing  Foreign Tax Credit: ITAT Delhi

Income Tax : Read the full text of the ITAT Delhi order in Suchi Agrawal vs. ITO, where the requirement of Form-67 for foreign tax credit was d...

June 24, 2024 483 Views 0 comment Print

Delhi ITAT Rules No Tax on Technical Services to AE Without PE in India

Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...

June 20, 2024 447 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 1989 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 828 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 594 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 2298 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 4191 Views 0 comment Print


Interpretation of Phrase “May be taxed” used in Paragraph 3 of Article 23 of India- UK DTAA, 1993

June 7, 2024 786 Views 0 comment Print

Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping tax treaties.

In absence of DTAA No tax on payments received by non-resident for IUC from Indian company

June 7, 2024 339 Views 0 comment Print

ITAT Bangalore ruled that payments received by a non-resident from an Indian company for interconnect utility charges cannot be taxed as royalty under section 9(1)(vi) of the Income Tax Act in the absence of a DTAA.

National Faceless Assessment Centre was Prescribed Income tax Authority for issuance of notice u/s 143(2)

June 6, 2024 1614 Views 0 comment Print

Assessee was a commercial bank having its head office in France and had 8 branches in India. Assessee was involved in normal banking activities including financing of foreign trade and foreign exchange transaction

TDS on Foreign Payments & Liquidated Damages as Capital Receipts

June 4, 2024 756 Views 0 comment Print

ITAT Kolkata ruled that TDS under section 195 is not required for foreign commission payments and liquidated damages are capital receipts, not taxable income.

CRM Services Receipts Not Taxable as Royalty or FTS: ITAT Delhi

June 4, 2024 237 Views 0 comment Print

In the case of Salesforce.com Singapore Pte Ltd. vs ACIT, ITAT Delhi ruled that receipts from CRM services aren’t taxable in India as royalty or FTS under the Income-tax Act or India-Singapore DTAA.

Joint Secretary’s Letter Can’t Override Income Tax Act: Calcutta HC

May 30, 2024 423 Views 0 comment Print

Calcutta High Court rules that a Joint Secretary’s letter cannot override the plain provisions of the Income Tax Act and Finance Act in the RBS N.V. vs CIT case.

Employee Salary Reimbursement Not Taxable as FTS under India-Japan DTAA

May 24, 2024 417 Views 0 comment Print

Understand the grounds of appeal in the case against the final assessment order under the Income Tax Act, 1961, for AY 2017-18, involving taxability of employee cost reimbursements and more.

Non-resident’s salary/allowances for services rendered abroad not taxable in India

May 23, 2024 3156 Views 0 comment Print

ITAT Delhi rules non-resident’s salary for services rendered abroad not taxable in India, providing significant relief under India-Australia DTAA.

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

May 18, 2024 468 Views 0 comment Print

In a landmark ruling, ITAT Mumbai provides relief to Shell IT, asserting that payments for IT support aren’t considered FTS under India-Netherlands DTAA.

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

May 6, 2024 426 Views 0 comment Print

Assessee was incorporated in Japan and was in the business of providing telecommunication services. Assessee provided fixed, mobile, wholesale, and associated telecommunication services across the globe.

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