Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...
Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...
Income Tax : This guide explains how the abolition of DDT shifted the tax burden on dividends from companies to shareholders from 1 April 2020 ...
Income Tax : The guide explains how residents can avoid double taxation through DTAA benefits, Foreign Tax Credit, and Section 91 relief, outli...
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 : 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 : ITAT Delhi held legal services are not FTS under Section 9(1)(vii) and directed partner-wise DTAA examination. FTS addition was de...
Income Tax : ITAT Mumbai allowed deduction of ESOP expenses under Section 37(1) by following Karnataka High Court's ruling in Biocon Ltd. Tribu...
Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...
Income Tax : ITAT Pune held that Foreign Tax Credit cannot be denied merely because Form 67 was filed after the prescribed due date. The Tribun...
Income Tax : The Delhi ITAT ruled that no installation or supervisory PE existed in India as the activities did not exceed the 120-day threshol...
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...
Understand Form 15CA/15CB and their filing process for cross-border transactions. Ensure compliance and transparency in international money transfers.
Read the detailed analysis of Sarva Capital LLC Vs ACIT (ITAT Delhi) regarding the validity of Tax Residency Certificate (TRC) for determining treaty benefits under the India-Mauritius Double Taxation Avoidance Agreement (DTAA).
Delhi High Court judgment in CIT vs. RELX Inc clarifies legal database subscriptions aren’t copyright transfers or royalty. Insights on taxation implications.
Delhi ITAT rules in favor of Volvo Information Technology AB, declaring receipts from Indian entities not taxable as royalty, aligning with SC precedents.
Learn about tackling tax avoidance in the UK with the Ramsay doctrine and GAAR. Explore their implications and effectiveness in combating tax avoidance strategies.
CIT Vs Mitsubishi Corporation India P. Ltd (Delhi High Court) The Delhi High Court deliberated on an appeal concerning Assessment Year (AY) 2006-07, where the Income Tax Appellate Tribunal (ITAT) had made decisions impacting the applicability of Section 40(a)(i) of the Income Tax Act, 1961, in relation to the Double Tax Avoidance Agreements (DTAAs) between […]
ITAT Delhi held that as conditions prescribed in exception to section 9(1)(vii)(b) stand fulfilled, it cannot be taxed as FTS. Further, the source for making or earning any income of the payer of fee for technical services, in the present case, is outside India, and therefore not taxable in India.
Explore the DCIT vs K.E. Faizal case where the ITAT Cochin ruled on taxation of mutual fund gains, analyzing the application of India-UAE Double Taxation Avoidance Agreement.
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).
Explore Supreme Court’s ruling on Most Favoured Nation clauses in Double Taxation Avoidance Agreements (DTAA). Learn impact, controversies, and implications of decision.
