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DTAA

Latest Articles


Essential Financial Steps and Tax Tips that every NRI’s must not miss

Finance : Discover essential financial steps and tax tips for NRIs, including converting accounts, trading restrictions, and leveraging DTAA...

July 18, 2024 717 Views 0 comment Print

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 660 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 882 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 6678 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 483 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 234 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 759 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 816 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 717 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 390 Views 0 comment Print


Latest Judiciary


Condition of ‘make available’ not satisfied hence technical service not taxable: ITAT Delhi

Income Tax : ITAT Delhi held that the condition of make available was not satisfied for services when provided by assessee did not enabled the ...

August 16, 2024 72 Views 0 comment Print

Domestic company paying DDT u/s. 115O doesn’t enter domain of DTAA: ITAT Pune

Income Tax : ITAT Pune held that the DTAA does not get triggered at all when a domestic company pays DDT u/s. 115O of the Income Tax Act. In nu...

August 16, 2024 78 Views 0 comment Print

Reassessment unsustained as based on entirely new reason which deprives assessee’s right to object: Delhi HC

Income Tax : Delhi High Court held that initiation of reassessment based on entirely new or previously undisclosed material or reasoning depriv...

August 12, 2024 192 Views 0 comment Print

No tax on amount paid for certification services rendered by foreign entities in absence of fixed place of business in India

Income Tax : Understand the Ahmedabad ITAT ruling that payments for certification services by foreign entities are not taxable in India without...

August 1, 2024 162 Views 0 comment Print

Additional grounds raised in appeal needs adjudication by lower authority: ITAT Chennai

Income Tax : ITAT Chennai restored the matter back to the file of AO for re-adjudication as additional ground raised by the assessee in appeal ...

July 26, 2024 654 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 2238 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 867 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 609 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 2403 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 4248 Views 0 comment Print


Addition towards cloud based services, not a royalty, not sustainable

July 18, 2022 765 Views 0 comment Print

Held that the authorities fallen in error in considering the subscription received towards cloud serviced to be royalty income

Taxability of NRIs in the light of India-Singapore DTAA

June 25, 2022 12816 Views 3 comments Print

Understand the taxability of NRIs in the light of India-Singapore DTAA. Learn about residential status, taxation laws, and investments in India and Singapore.

Income from technical handling services to other Airlines is exempt under Article 8 of India Netherlands DTAA

June 22, 2022 534 Views 0 comment Print

income from technical handling is exempt from taxation in India as the same is covered under Article 8 of the DTAA between India & Netherlands and hence not liable to tax in India.

ITAT explains impact on taxability when treaty not contains FTS clause

June 22, 2022 5457 Views 0 comment Print

DCIT Vs Michelin ROH Co. Ltd. (ITAT Delhi) Brief facts of the case are that the assessee has a company incorporated in Thailand and offers a number of services, such as, business planning and coordination, engineering services, product research and development etc. to its Indian subsidiary. On offering these engineering services, the assessee obtained a […]

Etymology of TP, Concept of AEs, International & Domestic Transaction

May 24, 2022 1620 Views 0 comment Print

Uncover the mysteries of transfer pricing and associate enterprises. Explore the etymology and concepts behind international and domestic transactions.

How did Adani strike a tax-free acquisition of Ambuja Cements & ACC !!

May 23, 2022 48492 Views 0 comment Print

Through this article, we aim to uncover the probable rationale and takeaways from this acquisition, for which we need to first understand the ownership structure of both the groups – Holcim and Adani.

Critical Analysis on Mandatory Binding Arbitration in India

May 18, 2022 2466 Views 0 comment Print

Explore the issue of mandatory binding arbitration in India and its critical analysis. Learn about the impact on double taxation avoidance agreements and dispute resolution mechanisms.

TDS Rate on subcontracting charges paid to Chinese subsidiary will be 10% instead of 20% under Indo-China DTAA

April 24, 2022 3441 Views 0 comment Print

Infosys Limited Vs DCIT (ITAT Bangalore) Conclusion: The applicable rate of TDS on subcontracting charges paid to Infosys China should be considered at 10% as per the India-China DTAA instead of 20% as per section 206AA. Held: Assessee was an Indian company, engaged in the business of development and export of computer software and related […]

Provisions of DTAA override section 206AA of Income Tax Act

April 20, 2022 2220 Views 0 comment Print

Infosys Limited Vs DCIT (ITAT Bangalore)  The relevant ground with regard to the above issue are grounds 9.1 to 9.3. The Special Bench of the Tribunal in the case of Nagarjuna Fertilizders and Chemicals Ltd. v. ACIT reported in (2017) 78 taxmann.com 264 had held if rate of tax applicable under DTAA is lower than […]

Performance Guarantee Commission cannot be reckoned as FTS

April 3, 2022 1068 Views 0 comment Print

Dynamic Drilling & Services Pvt. Ltd. Vs ACIT (ITAT Delhi) The only issue before us is, whether tax credit can be allowed to the assessee company on the income offered to tax in India on the tax deducted by the Singapore Company from the Performance Guarantee Commission during the year under assessment. The main reason […]

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