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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 4671 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 210 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 780 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 1533 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 1008 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 528 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 774 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 687 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 342 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 639 Views 0 comment Print


Latest Judiciary


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 408 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 474 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 330 Views 0 comment Print

Software Sales Not Royalty Income under India-Japan DTAA: ITAT Delhi

Income Tax : Analysis of ITAT Delhi's ruling: Sale of software products not taxable as royalty under India-Japan DTAA, citing Engineering Analy...

March 27, 2024 216 Views 0 comment Print

TDS u/s. 195 not deductible on expense of management and marketing support service paid to foreign company: ITAT Delhi

Income Tax : ITAT Delhi held that expense towards management and marketing support service paid to foreign company is not taxable under Fee for...

March 27, 2024 561 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 912 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 699 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 567 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 1866 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 3942 Views 0 comment Print


India and UAE DTAA not contain any article concerning FTS

January 23, 2023 2139 Views 0 comment Print

WTS Energy Dmcc Vs DCIT (Delhi High Court) Double Tax Avoidance Agreement obtaining between India and UAE does not contain any article concerning FTS. The petitioner, who is a non-resident and does not have a PE in India, claims that the subject income is “business income.”  It is because of these varying stands, that a […]

Foreign Tax Credit under DTAA cannot be denied for Delay in filing Form 67

January 22, 2023 4905 Views 0 comment Print

Rohan Hattangadi Vs CIT (A) (ITAT Mumbai) From Rule 128, it is evident that the assessee has to file Form 67 on or before the due date of furnishing the return of income as per section 139(1) of the Act, which the statement specifies as mandatory and not directory as per the word ‘shall’ used […]

Rendering of advisory service doesn’t amount to Fees for Included Services

January 19, 2023 1212 Views 0 comment Print

Calcutta High Court held that rendering of advisory service doesn’t amount to Fees for Technical Services/ Fees for Included Services under Article 12(4)(b) of the India-US Double Taxation Avoidance Agreement.

Business support services cannot be treated as Technical Services in absence of transfer of technology

January 19, 2023 654 Views 0 comment Print

Michael Page International Pte Limited Vs DCIT (ITAT Mumbai) ITAT held that unless the recipient of the services, by virtue of rendition of services by the assessee, is enabled to provide the same services without recourse to the service provider, the services cannot be said to have made available the recipient of services. A mere […]

Fees for training to Employees on soft skill & general topics cannot be treated as FTS

January 5, 2023 2655 Views 0 comment Print

ITAT held that payment of Fees for training to Employees on soft skill & general topics cannot be treated as Fees for Technical Services (FTS)

Foreign Tax Credit

January 4, 2023 3030 Views 0 comment Print

Do you know, there are two principles to tax income. One is Residence Based Taxation and other is Source Based Taxation. As per Residence based Taxation, the country taxes persons based on their residential status.

Rule 128(9) not provide for disallowance of Foreign Tax Credit in case of delay in filing Form 67

January 3, 2023 2232 Views 0 comment Print

Rule 128(9) of the Rules does not provide for disallowance of Foreign Tax Credit (FTC) in case of delay in filing Form 67

Interest on income tax refund taxable under Article 11(2) of India- Malaysia DTAA

January 2, 2023 879 Views 0 comment Print

Assessing Officer is directed to tax interest on income tax refund under Article 11(2) of India- Malaysia DTAA and not as Business Income

Guarantee commission not taxable in terms of India-Germany DTAA

December 29, 2022 1278 Views 0 comment Print

ITAT Mumbai held that transfer pricing adjustment on account of guarantee commission income is unsustainable in terms of India-Germany DTAA.

Interpretation of term contracting states mentioned under DTAA

December 29, 2022 7380 Views 1 comment Print

Clearing the understanding of term contracting states mentioned under DTAA between two countries with an interesting example. Learn what a contracting state is, and how it helps to avoid double taxation in two countries.