Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...
Income Tax : Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping...
Income Tax : Understanding taxation for NRIs: Learn about residential status, taxable income, deductions, and the importance of Double Taxation...
Income Tax : Explore the nexus between tax avoidance and inequality in India. Learn how legal loopholes deepen economic divides and discover st...
Income Tax : CIT – International Taxation Vs. ESPN Star Sports Mauritius S.N.C ET Compagnie (Delhi High Court) The Delhi HC affirms the o...
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 : CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modif...
Income Tax : ITAT Indore rules in Asha Rani Pandya Vs DCIT/ACIT that filing Form 67 for claiming Foreign Tax Credit (FTC) is a directory requir...
Income Tax : Read the full text of the ITAT Delhi order on Cricket Australia vs. ACIT (International Taxation). Analysis includes why license f...
Income Tax : For income to be taxable under FTS, there must be a direct enablement or transfer of skills or knowledge, which mere advisory or c...
Income Tax : Read the full text of the ITAT Delhi order in Suchi Agrawal vs. ITO, where the requirement of Form-67 for foreign tax credit was d...
Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...
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...
Income Tax : The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (part...
Trimble Solutions Corporation Vs DCIT (ITAT Mumbai) We find that the issue involved in the present appeal i.e as to whether the payments received by the assessee from its distributor for sale of specialized software and maintenance and support services (including upgrades) could be held as “royalty” as per Article 12 of the India-Finland tax […]
Indian Government has issued a Circular No. 2 of 2021 dated 3rd March, 2021 (Circular 2021) for determination of residency of individuals for the current tax year (PY 2020-2021) for individuals who were forced to remain in India due to suspension of international flights in light of the Novel Corona Virus (COVID-19). Circular 2021 comes […]
The Union Cabinet, chaired by the Prime Minister Shri Narendra Modi has approved anAgreement between the Republic of India and Saint Vincent and The Grenadines for the Exchange of Information and Assistance in Collection with respect to Taxes.
The Hon’ble Tribunal provided relief to the assesse for AY 2014-15 by making its reliance on section 90(2) of Act and observed that the provisions of the Act or the DTAA, whichever are more beneficial to the assessee would apply making the receipt from sale of software license as not chargeable to tax in India.
Income from cloud hosting services is erroneously held as royalty within the meaning of explanation 2 to section 9(l)(vi) of the Income Tax Act, 1961 (the Act) as well as Article 12(3)(b) of the India – US tax treaty
Interworld Shipping Agency LLC Vs DCIT (ITAT Mumbai) The short issue that we are actually required to adjudicate, in this appeal, is whether or not the authorities below were justified in declining the benefits of India UAE Double Taxation Avoidance Agreement [(1995) 205 ITR Stat 49; Indo-UAE tax treaty, in short] to the assessee appellant. […]
Ranjit Kumar Vuppu Vs ITO (ITAT Hyderabad) FULL TEXT OF THE ORDER OF ITAT HYDERABAD This is assessee’s appeal for the A.Y 2014-15 against the order of the CIT (A)-10, Hyderabad, dated 14.07.2020. 2. Brief facts of the case are that the assessee, a Non-resident individual, filed his return of income for the A.Y 2014-15 […]
Sri Vamsee Krishna Kundurthi Vs ITO (International Taxation) (ITAT Hyderabad) As the assessee has spent less than 60 days in India during the FY 2013-14, he qualifies as a Non resident under section 6(1) of the Act. Therefore, the foreign allowance of Rs.19,79,072/- was not offered to tax in India in the return of income […]
The provisions of the DTAA cannot be thrusted upon the Assessee simply because the Assessee is a tax resident of a country with which India has entered into a tax treaty or on account of the mere perception of the AO that the Assessee may claim benefits under the tax treaty in subsequent years. 2. Short term losses should be eligible to be carried forward.
CBDT notifies Agreement Between The Government Of The Republic Of India And The Government Of The Islamic Republic Of Iran For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income. Notification No. 29/2021-Income-tax Dated 1st April, 2021. MINISTRY OF FINANCE (Department of Revenue) New Delhi Notification No. […]
