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Switzerland Suspends Unilateral MFN Clause Application in Tax Treaty with India

Income Tax : Switzerland halts the unilateral application of the MFN clause under its tax treaty with India from 2025, following the Indian Sup...

March 4, 2025 270 Views 0 comment Print

Taxation of International Transactions In India Under Income Tax Act 1961

Income Tax : Learn how international transactions are taxed under India’s Income Tax Act, including DTAAs, transfer pricing, TDS provisions, ...

February 9, 2025 1947 Views 0 comment Print

How Switzerland revoking MFN Status with India linked to Nestle Case?

Income Tax : Switzerland suspends the MFN clause with India following a Supreme Court ruling in the Nestle case, impacting dividend tax rates f...

December 22, 2024 1104 Views 2 comments Print

Taxation of Indian & Overseas IPL Players

Income Tax : Explore the tax implications for IPL players, including income tax for Indian and overseas players, TDS rates, and the role of DTA...

December 18, 2024 2406 Views 0 comment Print

From Double Taxation to Treaty Shopping: Unfolding Saga of India-Mauritius DTAA

Income Tax : Explore the India-Mauritius DTAA's impact, treaty shopping challenges, and recent amendments aimed at preventing tax abuse and fos...

October 7, 2024 1173 Views 0 comment Print


Latest News


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 366 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 1014 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 828 Views 0 comment Print

Cabinet approves Agreement with Saint Vincent for Tax Information exchange

Income Tax : The Union Cabinet, chaired by the Prime Minister Shri Narendra Modi has approved anAgreement between the Republic of India and Sa...

June 23, 2021 723 Views 0 comment Print

CBDT releases MLI synthesised text for India-Czechoslovak Socialist Republic tax treaty

Income Tax : CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modif...

March 19, 2020 441 Views 0 comment Print


Latest Judiciary


No TDS on Payments to Non-Residents for Social Media Ads: Karnataka HC

Income Tax : Karnataka High Court held that TDS is not deductible on payment to non-residents for advertisements in several social medias like ...

February 22, 2025 201 Views 0 comment Print

Reimbursement of expense at cost not taxable as Fees for Technical Services

Income Tax : ITAT Mumbai held that that reimbursement of expenses at cost is not taxable as fees for technical services since there is no eleme...

February 15, 2025 213 Views 0 comment Print

Indian AE Transactions at Arm’s Length, HC Says No More Attribution

Income Tax : Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidia...

February 13, 2025 120 Views 0 comment Print

IT support payments not taxable as FTS due to failure of ‘make available’ test under India-UK DTAA: ITAT Delhi

Income Tax : ITAT Delhi rules IT support payments to CPP UK not taxable as fees for technical services due to failure of ‘make available’ t...

February 9, 2025 276 Views 0 comment Print

Carried forward losses cannot be set-off against exempt capital gains under DTAA

Income Tax : ITAT Mumbai ruled on TVF Fund Ltd’s appeal regarding tax loss set-off under DTAA. Key issues include carry-forward losses, taxab...

February 8, 2025 456 Views 0 comment Print


Latest Notifications


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 3267 Views 0 comment Print

CBDT Amends India-Spain Double Taxation Avoidance Agreement (DTAA)

Income Tax : Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and ch...

March 19, 2024 3309 Views 0 comment Print

CBDT notifies Tax Information Exchange Agreement: India-Samoa

Income Tax : Explore implications of Notification No. 21/2024 from Indias Ministry of Finance regarding the tax information exchange pact with ...

February 7, 2024 984 Views 0 comment Print

Income Tax Agreement Between India & Saint Vincent for information Exchange

Income Tax : Notification No. 96/2023-Income Tax: Learn about the agreement between India and Saint Vincent for tax information exchange and as...

November 1, 2023 660 Views 0 comment Print

DTAA between India and Chile notified by CBDT

Income Tax : Notification No. 24/2023- Income-Tax Dated: 03rd May, 2023 under section 90(1) of Income tax Act, 1961 regarding Agreement and Pro...

May 3, 2023 2997 Views 0 comment Print


Foreign Tax Credit eligible for taxes withheld in Japan: ITAT Mumbai

November 11, 2024 336 Views 0 comment Print

ITAT Mumbai held that services rendered by the appellant is taxable in Japan in accordance to Article 12 of the India-Japan DTAA hence Foreign Tax Credit ought to have been granted to Appellant for taxes withheld in Japan.

No TDS liability u/s 195 on sales commission paid to overseas subsidiary for non-technical services as same was not ‘FTS’

October 29, 2024 759 Views 0 comment Print

Sales and marketing services rendered to assessee by its US based subsidiary did not fall within the ambit of FTS as defined u/s 9(1)(vi) or Article 12 of India-US DTAA as  making available service did not make available knowledge, experience, skill etc.

Interest payments to China Development Bank exempt under India-China DTAA: Delhi HC

October 27, 2024 234 Views 0 comment Print

CDB qualifies as a financial institution wholly owned by Government of China, thereby making interest payments exempt from taxation under amended provisions of DTAA.

Taxation of shipping companies operating in international waters & applicability of India-Singapore DTAA

October 16, 2024 372 Views 0 comment Print

Atlantic Shipping Pvt. Ltd. Vs ITO (ITAT Rajkot) In a recent ruling by the Income Tax Appellate Tribunal (ITAT) in Rajkot, the case of Atlantic Shipping Pvt. Ltd. vs. Income Tax Officer has brought to light critical issues regarding tax assessments for shipping companies operating in international waters and the applicability of the India-Singapore Double […]

From Double Taxation to Treaty Shopping: Unfolding Saga of India-Mauritius DTAA

October 7, 2024 1173 Views 0 comment Print

Explore the India-Mauritius DTAA’s impact, treaty shopping challenges, and recent amendments aimed at preventing tax abuse and fostering genuine investments.

LLC as Fiscally Transparent Entity Under US Law eligible for India-USA DTAA Benefits

September 30, 2024 621 Views 0 comment Print

The article analyzes the treatment of LLCs under the India-USA DTAA, focusing on taxation implications for foreign entities in India.

Cloud Subscription Fees Not Royalty under India-Ireland DTAA: ITAT Delhi

September 30, 2024 387 Views 0 comment Print

ITAT Delhi rules that subscription fees from cloud services are not taxable as royalty under the India-Ireland DTAA. 

U.S. LLCs with Separate Legal Identity Eligible for Treaty Benefits: Key crux of General Motors case

September 25, 2024 897 Views 0 comment Print

Explore how LLCs qualify for India-US DTAA benefits, focusing on tax liability and resident status under Article 4 in the General Motors vs ACIT case.

Form No. 10F under the Income Tax Act

September 24, 2024 6411 Views 0 comment Print

Form No. 10F is a self-declaration for NRIs to claim benefits under DTAA when their Tax Residency Certificate lacks essential details.

Damages is capital receipt but interest on damages is revenue receipt: ITAT Delhi

September 24, 2024 516 Views 0 comment Print

ITAT Delhi held that damages are compensation received is a capital receipt, however, interest on damages is to be treated as revenue receipt hence the same is taxable.

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