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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 4572 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


BEPS Principles and MLI Framework in India’s PE Status under DTAA

January 15, 2024 2640 Views 0 comment Print

Explore the impact of BEPS principles and MLI framework on India’s Double Taxation Avoidance Agreements (DTAA). Detailed analysis of the India-Singapore DTAA, changes in PE clauses, and post-BEPS amendments.

Receipt in terms of Strategic Oversight Services Agreement cannot be termed as royalty

January 6, 2024 1290 Views 0 comment Print

Delhi High Court held that the consideration received in terms of Strategic Oversight Services Agreements (SOSA) cannot be termed as Royalty under Article 12 of the DTAA even if extensive services are rendered which includes access to written knowledge, processes, and commercial information in furtherance of the services.

Exploring The Emerging Areas of International Taxation

January 5, 2024 1431 Views 0 comment Print

Explore the dynamic landscape of international taxation, delving into emerging areas like digital companies, cross-border transactions with cryptocurrencies, and the evolving tax landscape for multinational corporations. Stay informed on transfer pricing regulations and ensure compliance for a seamless global business experience.

Form 10F Guide: Tax Treaty Benefits for Non-Resident Receiving Indian Income

January 5, 2024 33105 Views 3 comments Print

Understand Form 10F for non-residents receiving income from India. Learn about electronic filing, recent changes, and the benefits of claiming tax treaty relief with Tax Residency Certificate (TRC).

Decoding Grant Thornton Case: Impact on Cross-Border Transactions

January 4, 2024 1767 Views 0 comment Print

Explore Grant Thornton India LLP case, unraveling complex international tax issues. Analysis of arguments, rulings, and broader implications for businesses in cross-border transactions.

No Profit Attribution if Ricardo India’s Commission Adjusted: Delhi HC

January 2, 2024 855 Views 0 comment Print

Explore Delhi High Court’s ruling in CIT vs Ricardo U.K. Limited. No profit attribution if commission paid to Ricardo India is adjusted against PE profit. Detailed analysis and implications.

Taxation of IPL Income under Section 115BBA of Income Tax Act 1961 for Mitchell Starc & Pat Cummins

December 31, 2023 9918 Views 0 comment Print

Explore tax implications of Mitchell Starc and Pat Cummins’ Rs. 45.25 crores IPL earnings under Section 115BBA. Learn about TDS, exemptions, and dual taxation agreements between India and Australia.

Recent Developments in International Taxation: Analysis and Implications

December 30, 2023 4032 Views 0 comment Print

Explore the latest in international taxation: from judicial precedents to regulatory changes. Dive into cases, form updates, and MFN clause implications.

Fees for Domain Registration Not Royalty under Section 9(1)(vi): Delhi HC

December 25, 2023 1938 Views 0 comment Print

Explore Delhi High Court’s landmark decision on GoDaddy’s domain registration income. Learn why court ruled against treating it as royalty under Section 9(1)(vi) of Income Tax Act.

Disallowance of interest on loan given to subsidiary unjustified as investment was purely for commercial expediency

December 23, 2023 1890 Views 0 comment Print

ITAT Chennai held that disallowance of interest u/s 36(1)(iii) of the Income Tax Act on loans and advances given to subsidiary company unjustified as investment in subsidiary is purely for commercial expediency.

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