Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...
Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...
Income Tax : This guide explains how the abolition of DDT shifted the tax burden on dividends from companies to shareholders from 1 April 2020 ...
Income Tax : The guide explains how residents can avoid double taxation through DTAA benefits, Foreign Tax Credit, and Section 91 relief, outli...
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 : 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 : ITAT Delhi held legal services are not FTS under Section 9(1)(vii) and directed partner-wise DTAA examination. FTS addition was de...
Income Tax : ITAT Mumbai allowed deduction of ESOP expenses under Section 37(1) by following Karnataka High Court's ruling in Biocon Ltd. Tribu...
Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...
Income Tax : ITAT Pune held that Foreign Tax Credit cannot be denied merely because Form 67 was filed after the prescribed due date. The Tribun...
Income Tax : The Delhi ITAT ruled that no installation or supervisory PE existed in India as the activities did not exceed the 120-day threshol...
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...
ITAT Delhi held that the receipts from centralised service income are not taxable as Fees for Technical Services (FTS)/ Fees for included Services (FIS) under Article 12(4)(a) of India-USA DTAA.
Explore the key aspects and implications of the case Avaya International Sales Ltd Vs ACIT, wherein ITAT Delhi directed a fresh examination of the taxability of support/maintenance services under the India-Ireland DTAA.
A detailed analysis of the decision made by the Income Tax Appellate Tribunal (ITAT) Mumbai in the case of Ambuja Cements Limited Vs ACIT. The Tribunal allowed rectification of a mistake apparent from the record under section 254(2) of the Income Tax Act, 1961
Unlock insights into the increased tax rate on royalties and technical service fees in India post the Union Budget 2023-24. Understand the implications for non-residents and Indian companies, the role of Double Tax Avoidance Agreements, and the importance of filing Income Tax Returns. Get expert guidance on mitigating the impact and navigating the changing tax landscape.
ITAT Delhi held that Tax Residency Certificate (TRC) is statutorily the only evidence required to be eligible for the benefit under the DTAA. Accordingly, benefit of India-Mauritius DTAA duly available.
ITAT Mumbai held that fabrication charges received from Associate Enterprise doesn’t fall under the purview of fees for technical services (FTS) and accordingly not taxable in India.
Learn about the Foreign Account Tax Compliance Act (FATCA) non-tax treaty between India and the United States, its implications on reporting foreign assets, and taxation of investments in India by US tax residents. Understand the complexities of FATCA regulations and the need for expert advice.
ITAT Bangalore held that reimbursement of salary for seconded employee cannot be regarded as ‘Fee for technical services’ (FTS) under India-US Tax Treaty (DTAA).
ITAT Delhi held that global operation fees cannot be taxed as Fees for Technical Services (FTS) under the provisions of the Act and the India-UK DTAA as it doesn’t satisfy the ‘make available’ clause contained in Article 13(4)(c) of the India-UK DTAA.
ITAT Hyderabad held that FCCDs are debt hence interest paid/ payable on FCCDs in to be computed by applying LIBOR plus 200 basis points.
