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...
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.
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.
Bombay High Court rules HSBC Bank in Mauritius exempt from tax in India for bona fide banking business, impacting 2011-12 Assessment Year case.
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.
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.
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.
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.
Explore implications of Notification No. 21/2024 from Indias Ministry of Finance regarding the tax information exchange pact with Samoa. Learn more here.
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.
