Finance : On May 6, 2025, India and the United Kingdom officially concluded a comprehensive Free Trade Agreement (FTA), marking a significan...
Income Tax : Article explores effectiveness and influence of Bilateral Investment Treaties (BITs) on FDI flows with particular emphasis within ...
Income Tax : Switzerland halts the unilateral application of the MFN clause under its tax treaty with India from 2025, following the Indian Sup...
Income Tax : Learn how international transactions are taxed under India’s Income Tax Act, including DTAAs, transfer pricing, TDS provisions, ...
Income Tax : Switzerland suspends the MFN clause with India following a Supreme Court ruling in the Nestle case, impacting dividend tax rates f...
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 Union Cabinet, chaired by the Prime Minister Shri Narendra Modi has approved anAgreement between the Republic of India and Sa...
Income Tax : ITAT Mumbai held that head office expenditure incurred outside India exclusively for the Indian branches does not fall within the ...
Income Tax : Reimbursement of expenses qua marketing fees, frequent flyer programme, frequent guest programme and reservation fees received by ...
Income Tax : Delhi High Court dismisses revenue appeal against Bharti Airtel, reaffirming that charges paid for bandwidth to overseas operators...
Income Tax : Delhi High Court rules payments for hotel centralised services like marketing and reservations are not taxable as technical fees, ...
Income Tax : The present appeal has been preferred by the revenue. The controversy involved in the present appeals pertains to the treatment of...
Income Tax : Circular No. 01/2025 outlines the application of the Principal Purpose Test (PPT) under India's Double Taxation Avoidance Agreemen...
Income Tax : Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and ch...
Income Tax : Explore implications of Notification No. 21/2024 from Indias Ministry of Finance regarding the tax information exchange pact with ...
Income Tax : Notification No. 96/2023-Income Tax: Learn about the agreement between India and Saint Vincent for tax information exchange and as...
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...
ITAT Mumbai held that that reimbursement of expenses at cost is not taxable as fees for technical services since there is no element of income attached to the transaction. Accordingly, revenue’s appeal dismissed.
Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidiary of Adobe Software Trading Company Limited and Adobe Systems Incorporated is the ultimate parent company of ADIR.
ITAT Delhi rules IT support payments to CPP UK not taxable as fees for technical services due to failure of ‘make available’ test under India-UK DTAA.
Learn how international transactions are taxed under India’s Income Tax Act, including DTAAs, transfer pricing, TDS provisions, and compliance essentials.
ITAT Mumbai ruled on TVF Fund Ltd’s appeal regarding tax loss set-off under DTAA. Key issues include carry-forward losses, taxability, and judicial precedents.
ITAT Bangalore upheld CIT(A)’s decision, ruling that interconnect charges paid to A1 Telekom Austria are not taxable as royalty under the Income Tax Act or DTAA.
ITAT Delhi held that advertisement and distribution revenue earned by Discovery Asia Inc. is taxable as per Mutual Agreement Resolution (MAP) as decided by competent authority of India & USA. Accordingly, appeal allowed partially.
ITAT Chennai held that payments are in the nature of selling commission to foreign agents who is not having permanent establishment or business connection in India is not taxable in India and accordingly, TDS u/s. 195 not deductible.
Circular No. 01/2025 outlines the application of the Principal Purpose Test (PPT) under India’s Double Taxation Avoidance Agreements (DTAAs) for treaty compliance.
In the event and income sourced in India was not characterized under the heads provided in the DTAA, the income would be taxable under the residual clause provided taxing right was allocated to source country in this case to India under the relevant DTAA.
