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Taxation for NRIs

Income Tax : Understanding taxation for NRIs: Learn about residential status, taxable income, deductions, and the importance of Double Taxation...

April 19, 2024 5334 Views 0 comment Print

Tax Avoidance and Inequality: Connecting the Dots in India

Income Tax : Explore the nexus between tax avoidance and inequality in India. Learn how legal loopholes deepen economic divides and discover st...

April 19, 2024 315 Views 0 comment Print

Payments made under distribution agreement not taxable in India: Delhi HC

Income Tax : CIT – International Taxation Vs. ESPN Star Sports Mauritius S.N.C ET Compagnie (Delhi High Court) The Delhi HC affirms the o...

March 23, 2024 858 Views 0 comment Print

Key Provisions and Implications of India-USA Tax Treaty

Income Tax : Explore the India-USA Tax Treaty, its provisions, implications, and how it prevents double taxation. Learn about residency, taxati...

March 18, 2024 2166 Views 1 comment Print

Foreign Tax Credit (FTC): Importance, Concept and How to Claim FTC

Income Tax : Understanding Foreign Tax Credit (FTC) in India: Learn its significance, rules, claiming procedure, case law insights, and steps t...

March 18, 2024 1191 Views 0 comment Print

Latest News

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 555 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 780 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 696 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 348 Views 0 comment Print

CBDT releases MLI synthesised text for India-Poland tax treaty

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

March 19, 2020 648 Views 0 comment Print

Latest Judiciary

IT Support Payments Not FTS under Article 12 of India-Netherlands DTAA

Income Tax : In a landmark ruling, ITAT Mumbai provides relief to Shell IT, asserting that payments for IT support aren't considered FTS under ...

May 18, 2024 156 Views 0 comment Print

Amount received towards Interconnectivity Utility charges from Indian Customers was not taxable as Royalty

Income Tax : Assessee was incorporated in Japan and was in the business of providing telecommunication services. Assessee provided fixed, mobil...

May 6, 2024 321 Views 0 comment Print

ITAT Ruling on Taxability of FTS, in absence of specific clause in DTAA

Income Tax : Learn about the tax dispute between Diamond Manufacturing Management and the Indian Revenue Authority, involving fees for technica...

April 21, 2024 588 Views 0 comment Print

Disallowance u/s 14A deleted as interest free own funds exceeded investment: ITAT Mumbai

Income Tax : ITAT Mumbai held that disallowance made u/s. 14A of the Income Tax Act read with rule 8D deleted as tax free funds were more than ...

April 5, 2024 507 Views 0 comment Print

Sale of Online Advertisement Space Not Taxable as Royalty or FTS in India: ITAT Bangalore

Income Tax : ITAT Bangalore held that payment made by Google India Pvt. Ltd. to Google Ireland Limited (assessee) for sale of online advertisem...

April 2, 2024 399 Views 0 comment Print

Latest Notifications

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 1275 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 750 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 579 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 1971 Views 0 comment Print

Clarification on Most-Favoured-Nation clause in Protocol to India’s DTAAs

Income Tax : The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (part...

February 3, 2022 4041 Views 0 comment Print

Income from bandwidth services provided outside India cannot be taxed as ‘Royalty’ under India-Singapore DTAA

October 22, 2020 2127 Views 0 comment Print

Income received on providing bandwidth services outside India was not taxable as ‘Royalty’ under India-Singapore Double Taxation Avoidance Agreement (DTAA) as mere receipt of service using equipment under the control, possession and operation of service provider would only be considered as transaction of a service and not to ‘use or right to use’ an equipment, and would not attract ‘Royalty’ under the Act or the Tax Treaty.

Income for Sale of Specialized Software Maintenance & Support Services is Not a Royalty

October 16, 2020 1431 Views 0 comment Print

The issue under consideration is whether the Income received for sale of specialized software and maintenance and support services is considered as ‘Royalty’ as per India-Finland Tax Treaty?

No TDS on commission paid to non-resident agent for effecting exports

October 13, 2020 3579 Views 0 comment Print

Device Driven (India) Pvt. Ltd. Vs CIT (Kerala High Court) No TDS on commission paid to non-resident agent for effecting exports as it was not taxable under Income Tax Act Conclusion: Services rendered for effecting exports within India by assessee-company to foreign buyers would not attract income tax since the income was derived from the […]

Understanding DTAA with Case Laws

October 9, 2020 108889 Views 6 comments Print

There are two kinds of DTAA. Comprehensive Agreements & Limited Agreements. Comprehensive Agreements scope is to addressing all source of income whereas Limited Agreements scope to cover only. (a) Income from Operation of Aircrafts & Ships (b) Estates (c) Inheritance & (d) Gifts. Currently there are 90 Comprehensive Agreements & 13 Limited Agreements India.

Section 91: Assessee entitled to foreign tax credit of federal as well as state taxes

September 19, 2020 4098 Views 0 comment Print

Aditya Khanna Vs DDIT (ITAT Delhi) The Income-tax in relation to any country includes Income-tax paid in any part of the country or a local authority. It applies to cases where in a federal structure a citizen is made to pay federal Income-tax and also the State income tax. The Income-tax in relation to any […]

Modification due to Notification has Effect of Deleting Old Rule & Making New Rule Operative

September 15, 2020 759 Views 0 comment Print

whether the Tribunal was correct in holding that the assessee is liable to be taxed at 10% in view of replacement of 15% with 10% of tax in Article 12 of the DTAA without taking into consideration that the modification of rate of tax by way of notification?

Tax Treaties and Investments Made Outside India

September 7, 2020 2148 Views 0 comment Print

Nations around the world engage in many kinds of agreements related to financial matters. Such treaties and agreements prove to be beneficial for the residents (individuals as well as business entities) of those countries who are active parties in the agreement. They can provide a tax credit, tax exemptions, and an overall cut in the […]

Sale of software- Transfer of copyright or transfer of a copyrighted article?

August 28, 2020 5175 Views 0 comment Print

Since past two-decade, software industry has undergone tremendous technological changes and accordingly such industry has emerged to be one of the fastest growing industry worldwide. India being a developing country provides ample opportunities for Multi-national Enterprises (MNEs) to expand their business in India. The technological advancement has acquainted such MNEs to expand with negligible physical […]

Architectural Services provided to Singapore Entity Taxable at 10% when DTAA Benefit is Available

August 24, 2020 1374 Views 0 comment Print

The issue under consideration is whether the architectural services provided to Singapore Entity taxable at 10% or 20% when the benefit of Double Taxation Avoidance Agreement (DTAA) is available?

ITAT refer TP adjustment for Notional Interest to Special Bench

August 20, 2020 1197 Views 0 comment Print

The issue under consideration is whether transfer pricing adjustment as notional interest and charging it to tax, disregarding the provisions of Article 11 of India Cyprus DTAA is justified in law?

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May 2024