Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...
Income Tax : Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping...
Income Tax : Understanding taxation for NRIs: Learn about residential status, taxable income, deductions, and the importance of Double Taxation...
Income Tax : Explore the nexus between tax avoidance and inequality in India. Learn how legal loopholes deepen economic divides and discover st...
Income Tax : CIT – International Taxation Vs. ESPN Star Sports Mauritius S.N.C ET Compagnie (Delhi High Court) The Delhi HC affirms the o...
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 : The Union Cabinet, chaired by the Prime Minister Shri Narendra Modi has approved anAgreement between the Republic of India and Sa...
Income Tax : CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modif...
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...
Income Tax : Read the full text of the ITAT Delhi order on Cricket Australia vs. ACIT (International Taxation). Analysis includes why license f...
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...
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...
Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...
Income Tax : Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and ch...
Income Tax : Explore implications of Notification No. 21/2024 from Indias Ministry of Finance regarding the tax information exchange pact with ...
Income Tax : Notification No. 96/2023-Income Tax: Learn about the agreement between India and Saint Vincent for tax information exchange and as...
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...
Income Tax : The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (part...
ITAT Delhi held that amount received by the assessee from providing SAP support services and IT support services is not covered within the purview of Fees for Technical Services (FTS) and hence not taxable in India in absence of permanent establishment.
ITAT Delhi held that the amount of received in the arbitration settlement is related to project office of the assessee company in India. Accordingly, the same is taxable in India.
Linklaters LLP Vs Asst Vs CIT (IT)-3(1)(2) Mumbai (ITAT Mumbai) ITAT Mumbai held that remuneration received for providing legal services doesn’t amount to ‘fees for technical services’, where the provisions of section 9(1)(vii) of the Act is not applicable. Accordingly, the same is not taxable. Facts- The assessee is a LLP incorporated under the laws […]
Understand the differences between the UN and OECD Model Tax Conventions and their application in Indian tax treaties. Dive into article-by-article comparisons and India’s unique tax treaty policies.
ITAT Delhi held that the provisions of a DTAA (Double Taxation Avoidance Agreement) supersedes the provisions of the income tax Act in case their application is more beneficial.
ITAT held that receipts from Satellite Transmission Services cannot be treated as royalty & not taxable at the hands of assessee in India
When software itself is not taxable, the training and related activities concerned with utilization & installation cannot be held to be FTS.
ITAT Delhi held that amount received on account of business support services cannot be treated as ‘Fees for Technical Services’ (FTS) under Article 12(5) of India Netherlands DTAA and hence addition towards the same unsustainable.
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.
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.
