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DTAA

Latest Articles


Form 10F Mandatory for Claiming DTAA Benefits in India

Income Tax : Understand role of Form 10F for non-residents to claim Double Taxation Avoidance Agreement (DTAA) benefits and avoid higher withho...

June 8, 2025 1509 Views 0 comment Print

Key ITAT Rulings: Reassessment, Section 80G, DTAA & Transfer Pricing

Income Tax : Explore recent ITAT judgments on reassessment validity, 80G exemptions, DTAA interpretation for online education (FTS/Royalty), tr...

June 7, 2025 627 Views 0 comment Print

Software payments aren’t “royalty” if no copyright is transferred: SC

Income Tax : SC ruling clarifies software payments aren't royalty if no copyright is transferred. DTAA compliance, including TRC and Form 10F, ...

June 3, 2025 1893 Views 0 comment Print

Case Study: India-Mauritius Double Taxation Avoidance Agreement (DTAA)

Corporate Law : Explore the India-Mauritius DTAA's evolution, from its initial capital gains exemption to the 2016 amendments addressing tax avoid...

May 31, 2025 420 Views 0 comment Print

GAAR vs. DTAA: Clash of Domestic Anti-Avoidance Provisions and International Commitments

Income Tax : Explore the clash between India's GAAR and DTAAs, examining how domestic anti-avoidance provisions interact with international tax...

May 24, 2025 591 Views 0 comment Print


Latest News


CBDT Clarifies Guidance on Principal Purpose Test (PPT)

Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...

March 17, 2025 1512 Views 0 comment Print

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 429 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 1110 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 849 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 732 Views 0 comment Print


Latest Judiciary


AWS Cloud Computing Service Receipt Not Taxable as Equipment Royalty: Delhi HC

Income Tax : The charges paid by the Assessee’s customers are for availing services, which the Assessee provides by using its proprietary equ...

June 13, 2025 114 Views 0 comment Print

Online Course Fees Not FIS/Royalty: No Copyright or Technical Expertise

Income Tax : Delhi ITAT rules Coursera's online course receipts from India are not taxable as Fees for Included Services, citing prior judicial...

June 9, 2025 147 Views 0 comment Print

AO Exceeded Jurisdiction by Reclassifying Royalty Income as FTS: ITAT Bangalore

Income Tax : Bangalore ITAT rules AO exceeded jurisdiction by reclassifying online education income as FTS after a limited remand, deleting the...

June 4, 2025 198 Views 0 comment Print

Income from non-domain services not taxable as FTS/FIS under India-USA DTAA

Income Tax : ITAT Delhi rules GoDaddy's income from domain registration and web services is not taxable as royalty or FTS/FIS, citing judicial ...

May 15, 2025 567 Views 0 comment Print

Section 44C Inapplicable to Exclusive Head Office Expenses for Indian Branches Abroad

Income Tax : ITAT Mumbai held that head office expenditure incurred outside India exclusively for the Indian branches does not fall within the ...

May 12, 2025 168 Views 0 comment Print


Latest Notifications


Guidance on Principal Purpose Test (PPT) in India’s DTAAs

Income Tax : Circular No. 01/2025 outlines the application of the Principal Purpose Test (PPT) under India's Double Taxation Avoidance Agreemen...

January 21, 2025 3858 Views 0 comment Print

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 3528 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 1044 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 729 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 3153 Views 0 comment Print


Hotel Reimbursement of Marketing & Other Fees Not Fee for Technical Services

May 9, 2025 255 Views 0 comment Print

Reimbursement of expenses qua marketing fees, frequent flyer programme, frequent guest programme and reservation fees received by assessee cannot be treated as fee for technical services: HC

Bandwidth Charges Not Royalty Under Income Tax Act: Delhi HC

May 9, 2025 231 Views 0 comment Print

Delhi High Court dismisses revenue appeal against Bharti Airtel, reaffirming that charges paid for bandwidth to overseas operators are not taxable as royalty under the Income Tax Act.

Hotel Services Fee Not Taxable as Technical Fees: Delhi HC

May 9, 2025 369 Views 0 comment Print

Delhi High Court rules payments for hotel centralised services like marketing and reservations are not taxable as technical fees, citing prior judgment.

India-UK FTA : A Strategic Leap Towards Viksit Bharat 2047

May 7, 2025 309 Views 0 comment Print

On May 6, 2025, India and the United Kingdom officially concluded a comprehensive Free Trade Agreement (FTA), marking a significant advancement in bilateral economic relations.

Subscription fees for e-magazine doesn’t partake character of Fee for Technical Service

May 5, 2025 243 Views 0 comment Print

The present appeal has been preferred by the revenue. The controversy involved in the present appeals pertains to the treatment of “commission income” and the amounts received by the Assessee as “subscription fee”.

Intra-Group Services Not Taxable in India as They Fall Outside FTS Scope: ITAT Delhi

April 29, 2025 240 Views 0 comment Print

ITAT Delhi held that services rendered under Intra Group Service Agreement do not make available technical knowledge and hence would not fall within the definition of FTS as provided under Article 13(4) of India UK DTAA and hence not taxable in India.

Interest Payments to CDB Exempt under Article 11(3) of India-China DTAA

April 29, 2025 87 Views 0 comment Print

ITAT Delhi dismisses Revenue’s appeal against Tata Teleservices on taxability of interest paid to China Development Bank under India-China DTAA Article 11(3).

Disallowance u/s. 40(a)(i) for non-deduction of TDS from foreign remittance restored back to AO

April 24, 2025 1437 Views 0 comment Print

The assessee is carrying on business activity of export of software development and distinct services as Proprietor of Versatiletech. The return was picked up for scrutiny for the reason of compliance with TDS provisions and also foreign outward remittances.

Exempt LTCG Under India-Mauritius DTAA Not Adjustable Against Taxable Losses: ITAT Mumbai

April 22, 2025 126 Views 0 comment Print

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.

Planning, HR, Legal & IT Support Not Taxable as FTS Under India-USA DTAA, Citing ‘Make Available’ Test

April 20, 2025 498 Views 0 comment Print

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.

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