Follow Us:

DTAA

Latest Articles


Form 41 for DTAA Claims: Complete Guide under Income Tax Act 2025  

Income Tax : Form 41 is now compulsory for non-residents claiming DTAA benefits, replacing Form 10F. The update mandates online filing and ensu...

April 18, 2026 6468 Views 0 comment Print

Mauritius Route Hit: SC Rejects Tiger Global’s Treaty Claim in ₹14,439 Cr Flipkart Deal

Income Tax : The Court held that indirect share transfers deriving value from Indian assets are taxable. Treaty benefits were denied due to tax...

April 12, 2026 1161 Views 0 comment Print

Double Taxation Avoidance Agreement (DTAA) & Foreign Tax Credit (FTC)

Income Tax : Income Tax Department Ministry of Finance, Government of India DTAA & FTC Double Taxation Avoidance Agreement (DTAA) & For...

April 9, 2026 4575 Views 0 comment Print

Income Tax Appeals & Revision across different Appellate Levels

Income Tax : The case explains the statutory framework governing appeals and revisions under the Income-tax Act. It highlights the role of face...

April 9, 2026 1530 Views 0 comment Print

Cross-Border ESOPs: Tax, DTAA & TP Implications for Indian Employees & Subsidiaries

Income Tax : The article explains how ESOP taxation spans salary, capital gains, DTAA, and disclosure requirements. It highlights that errors i...

March 26, 2026 831 Views 0 comment Print


Latest News


India–France DTAA Amended to Grant Source Country Taxing Rights on Share Capital Gains

Income Tax : India and France have signed a protocol granting full taxing rights on capital gains from share sales to the country of company re...

February 24, 2026 1236 Views 0 comment Print

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 2646 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 813 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 1830 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 1041 Views 0 comment Print


Latest Judiciary


Foreign Tax Credit Cannot Be Denied Merely for Late Filing of Form 67: ITAT Delhi

Income Tax : The Delhi ITAT held that belated filing of Form No. 67 is only a procedural lapse and cannot extinguish substantive Foreign Tax Cr...

May 9, 2026 213 Views 0 comment Print

Cloud Service Payments Not Taxable as Royalty Due to No Transfer of IP Rights: SC

Income Tax : The Supreme Court affirmed that payments for cloud computing services are not royalty where no intellectual property rights are tr...

April 29, 2026 432 Views 0 comment Print

Only Legitimate Tax Can Be Collected; ITAT Restores BBC Distribution Fee Royalty Taxability Issue

Income Tax : The Tribunal set aside the dismissal of a delayed appeal, holding that the issue of distribution fee taxability requires fresh exa...

April 29, 2026 282 Views 0 comment Print

No FTS on Project-Specific Design Services; ‘Make Available’ Test Not Met, No Disallowance u/s 40(a)(i)

Income Tax : The Tribunal held that consultancy payments for architectural services were not FTS since no technical knowledge was made availabl...

April 16, 2026 210 Views 0 comment Print

Foreign Investor Gains Not Taxable in India Due to DTAA Residency Rule: ITAT Mumbai

Income Tax : The tribunal held that gains from sale of shares did not fall under Article 14(4). It ruled that Article 14(6) applies, making gai...

April 6, 2026 756 Views 0 comment Print


Latest Notifications


CBDT Notifies India-Japan Tax Recovery Pact

Income Tax : The government enforced a tax collection assistance agreement with Japan effective from 8 July 2025. The notification enables cros...

April 2, 2026 708 Views 0 comment Print

CBDT notifies amended India-Brazil Tax Treaty

Income Tax : The amendment expands the definition of permanent establishment to include service-based activities exceeding 183 days. It clarifi...

March 30, 2026 630 Views 0 comment Print

India Enforces Amended DTAA with Belgium from June 2025 to Curb Tax Evasion

Income Tax : The Finance Ministry notifies the India-Belgium protocol amending the 1993 tax treaty, effective June 26, 2025, updating definitio...

November 10, 2025 1059 Views 0 comment Print

India–Qatar DTAA & Protocol Notified by CBDT

Income Tax : Notification implements the India-Qatar Double Taxation Avoidance Agreement (DTAA) and Protocol, effective from the next fiscal ye...

October 24, 2025 1578 Views 0 comment Print

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 5457 Views 0 comment Print


Leveraging DTAA to Minimize Capital Gain Taxes for NRIs

February 19, 2024 8259 Views 1 comment Print

Learn how Non-Resident Indians (NRIs) in Germany, Singapore, UAE, Netherlands, and more can reduce capital gain taxes in India using Double Tax Avoidance Agreements (DTAA).

Decoding SC Judgement on MFN Clauses in DTAA

February 18, 2024 4161 Views 0 comment Print

Explore Supreme Court’s ruling on Most Favoured Nation clauses in Double Taxation Avoidance Agreements (DTAA). Learn impact, controversies, and implications of decision.

Sale of Software License Not Royalty under India-Singapore DTAA: ITAT Delhi

February 15, 2024 1128 Views 0 comment Print

ITAT Delhi rules receipts from the sale of software licenses to Pepsico India and ITC Limited not royalty under India-Singapore DTAA. Read the full analysis.

Management Fee Treated as Interest: Exemption under India-Germany DTAA

February 14, 2024 1098 Views 0 comment Print

Delhi ITAT rules management fee on ECB falls under ‘interest’ as per Sec 2(28A), exempt under India-Germany DTAA Art.11, aiding Aka Ausfuhrrkreditgesellschaft MBH.

HSBC Bank in Mauritius exempt from tax in India for bona fide banking business

February 14, 2024 1029 Views 0 comment Print

Bombay High Court rules HSBC Bank in Mauritius exempt from tax in India for bona fide banking business, impacting 2011-12 Assessment Year case.

Subscription, professional and training services not FTS hence not taxable: ITAT Delhi

February 13, 2024 1848 Views 0 comment Print

ITAT Delhi held that subscription, professional and training services rendered by the assessee do not fall within the definition of FTS under India-Netherland DTAA and, therefore, cannot be taxed in India.

Article 13(4) of India-Mauritius DTAA exempts sale of shares acquired prior to 1st April 2017

February 10, 2024 1653 Views 0 comment Print

ITAT Mumbai held that benefit of Article 13(4) of India Mauritius tax Treaty duly available to Mauritius registered assessee, having Tax Residency Certificate, for sale of shares which were acquired prior to 1st April 2017.

Obligation of Foreign Company to file Income Tax return of India

February 8, 2024 15525 Views 0 comment Print

Explore the legal framework, exemptions, and compliance challenges surrounding the obligation of foreign companies to file income tax returns in India. Learn about transfer pricing requirements and the implications of non-compliance.

GSMA vs DCIT: ITAT Rules No Royalty on IMEI Database Fees

February 8, 2024 843 Views 0 comment Print

ITAT Delhi rules in favor of GSMA Limited. Administrative fees for IMEI database access not deemed royalty. Detailed analysis of the order and tax implications.

CBDT notifies Tax Information Exchange Agreement: India-Samoa

February 7, 2024 1392 Views 0 comment Print

Explore implications of Notification No. 21/2024 from Indias Ministry of Finance regarding the tax information exchange pact with Samoa. Learn more here.

Search Post by Date
May 2026
M T W T F S S
 123
45678910
11121314151617
18192021222324
25262728293031