Income Tax : Form 41 is now compulsory for non-residents claiming DTAA benefits, replacing Form 10F. The update mandates online filing and ensu...
Income Tax : The Court held that indirect share transfers deriving value from Indian assets are taxable. Treaty benefits were denied due to tax...
Income Tax : Income Tax Department Ministry of Finance, Government of India DTAA & FTC Double Taxation Avoidance Agreement (DTAA) & For...
Income Tax : The case explains the statutory framework governing appeals and revisions under the Income-tax Act. It highlights the role of face...
Income Tax : The article explains how ESOP taxation spans salary, capital gains, DTAA, and disclosure requirements. It highlights that errors i...
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...
Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...
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 Delhi ITAT held that belated filing of Form No. 67 is only a procedural lapse and cannot extinguish substantive Foreign Tax Cr...
Income Tax : The Supreme Court affirmed that payments for cloud computing services are not royalty where no intellectual property rights are tr...
Income Tax : The Tribunal set aside the dismissal of a delayed appeal, holding that the issue of distribution fee taxability requires fresh exa...
Income Tax : The Tribunal held that consultancy payments for architectural services were not FTS since no technical knowledge was made availabl...
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...
Income Tax : The government enforced a tax collection assistance agreement with Japan effective from 8 July 2025. The notification enables cros...
Income Tax : The amendment expands the definition of permanent establishment to include service-based activities exceeding 183 days. It clarifi...
Income Tax : The Finance Ministry notifies the India-Belgium protocol amending the 1993 tax treaty, effective June 26, 2025, updating definitio...
Income Tax : Notification implements the India-Qatar Double Taxation Avoidance Agreement (DTAA) and Protocol, effective from the next fiscal ye...
Income Tax : Circular No. 01/2025 outlines the application of the Principal Purpose Test (PPT) under India's Double Taxation Avoidance Agreemen...
Read the detailed analysis of ITAT Delhi’s order in Cameron (Singapore) vs ACIT case. Learn why management support fees are not considered FTS under India-Singapore DTAA. Get insights on grounds, TDS credit, interest, and penalty.
ITAT Delhi rules in Amit Laroya vs ACIT case, stating salary of a Korean resident for services outside India is not taxable in India under Article 15(1) of India-Korea DTAA.
Delhi High Court’s judgment in CIT vs. Fox Network Group Singapore PTE Ltd. clarifies income tax treatment of live transmission fees under Income Tax Act Section 9(1)(vi).
This article sheds light on the concept of Significant Economic Presence (SEP) under Section 9 of the Indian Income Tax Act, 1961, and its implications for non-residents.
Explore Sennheiser Electronics India vs Circle – 4 case at ITAT Delhi. Section 115-O rate applies for additional tax on dividends to non-residents, not DTAA rate.
ITAT Delhi held that broadcasting “Live events” does not amount to a work in which copyright subsists i.e., “Live Rights”, is not “copyright” and therefore any payment made thereto can’t be said to be chargeable to tax as royalty under section 9(1)(vi).
Explore the impact of Double Taxation on international business, the role of Double Taxation Avoidance Agreements (DTAA), benefits, and case laws. Learn how to apply DTAA for tax relief
Delhi High Court upholds ITAT order: Payments received for software sale/supply not considered royalty under India-Singapore Double Taxation Avoidance Agreement (DTAA).
Explore the Madras High Court’s ruling on Section 248’s inapplicability to dividend declarations. Detailed analysis and implications of the judgment.
Delhi High Court disposes of CIT Vs Zaheer Mauritius appeals, addressing taxability and capital gains nature of Compulsorily Convertible Debentures under India-Mauritius DTAA.
