Income Tax : Form 41 is now compulsory for non-residents claiming DTAA benefits, replacing Form 10F. The update mandates online filing and ensu...
Income Tax : The Court held that indirect share transfers deriving value from Indian assets are taxable. Treaty benefits were denied due to tax...
Income Tax : Income Tax Department Ministry of Finance, Government of India DTAA & FTC Double Taxation Avoidance Agreement (DTAA) & For...
Income Tax : The case explains the statutory framework governing appeals and revisions under the Income-tax Act. It highlights the role of face...
Income Tax : The article explains how ESOP taxation spans salary, capital gains, DTAA, and disclosure requirements. It highlights that errors i...
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...
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 Delhi ITAT held that belated filing of Form No. 67 is only a procedural lapse and cannot extinguish substantive Foreign Tax Cr...
Income Tax : The Supreme Court affirmed that payments for cloud computing services are not royalty where no intellectual property rights are tr...
Income Tax : The Tribunal set aside the dismissal of a delayed appeal, holding that the issue of distribution fee taxability requires fresh exa...
Income Tax : The Tribunal held that consultancy payments for architectural services were not FTS since no technical knowledge was made availabl...
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...
Income Tax : The government enforced a tax collection assistance agreement with Japan effective from 8 July 2025. The notification enables cros...
Income Tax : The amendment expands the definition of permanent establishment to include service-based activities exceeding 183 days. It clarifi...
Income Tax : The Finance Ministry notifies the India-Belgium protocol amending the 1993 tax treaty, effective June 26, 2025, updating definitio...
Income Tax : Notification implements the India-Qatar Double Taxation Avoidance Agreement (DTAA) and Protocol, effective from the next fiscal ye...
Income Tax : Circular No. 01/2025 outlines the application of the Principal Purpose Test (PPT) under India's Double Taxation Avoidance Agreemen...
An in-depth analysis of the ITAT Chennai’s decision on ITO vs Eshakti Com Pvt Ltd, focusing on the deletion of disallowance under section 40(a)(i) of the Income Tax Act.
ITAT Bangalore held that in case of non-resident, income arising in India by way of royalties or technical charges could be taxed in India but that could be only on the receipt basis under India-Switzerland DTAA and not on accrual basis.
A detailed look at the recent ITAT Ahmedabad ruling in the case of Manoj Kaushikprasad Jingar Vs Assessing Officer. Explore how the tribunal addresses the issue of late filing of Form No.67 under the India-Tanzania DTAA.
ITAT Delhi held that as there is no copyright on live events, the license fees for live and non-live transmission right cannot be taxed as royaty in terms of section 9(1)(vi) of the Income Tax Act. Accordingly, addition deleted.
ITAT Bangalore held that payments received by assessee towards interconnectivity utility charges from Indian customers / end users cannot be considered as Royalty / FTS to be brought to tax in India under section 9(1)(vi)/(vii) of the Act and also as per DTAA.
ITAT Delhi rules that receipts from reselling hardware and software packages by Avnet Asia Pte Ltd aren’t considered ‘Royalty’ under India-Singapore DTAA.
ITAT Mumbai’s ruling in Spark44 vs. ACIT case highlights failure to consider India UK DTAA provisions for tax deduction on FTS. Analysis and conclusion included.
ITAT Mumbai held that cost reimbursement received towards providing support services is taxable as Fees for Technical Services (FTS) both under Section 9(1) (vii) of the Act as well as Article 12(4) of the Double Taxation Avoidance Agreement.
ITAT Delhi held that cost to cost reimbursement on account of secondment of employees cannot be treated as Fees for Technical Services (FTS) as defined under Article 12 of India USA-Double Tax Avoidance Agreement (DTAA).
Read the analysis of SPI Global US vs ACIT (ITAT Delhi) case where sub-contracting charges taxability under India-USA DTAA was contested. Learn about the make available clause and the final decision.
