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Interpretation of Phrase “May be taxed” used in Paragraph 3 of Article 23 of India- UK DTAA, 1993

Income Tax : Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping...

June 7, 2024 645 Views 0 comment Print

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 5604 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 387 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 939 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 2832 Views 1 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 627 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 792 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 699 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 360 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 657 Views 0 comment Print


Latest Judiciary


Section 270AA Penalty Immunity Application Cannot Be Rejected on Insufficient Grounds or Vague SCNs

Income Tax : Delhi High Court judgment on GE Capital vs. DCIT, distinguishing under-reporting and misreporting as separate offenses, resulting ...

June 13, 2024 219 Views 0 comment Print

Guarantee Commission Charges taxable in India as “other income” under Article 23(3) of Indo-UK DTAA

Income Tax : Guarantee commission charges received by a foreign parent company from its Indian subsidiaries were taxable in India, not as inter...

June 12, 2024 285 Views 0 comment Print

Subsidiary would only be deemed a PE if it satisfies specific tests outlined in DTAA

Income Tax : Delhi High Court quashes reassessment notices by DCIT after TPO settles arm's length remuneration issue. Detailed analysis of Prog...

June 9, 2024 330 Views 0 comment Print

In absence of DTAA No tax on payments received by non-resident for IUC from Indian company

Income Tax : ITAT Bangalore ruled that payments received by a non-resident from an Indian company for interconnect utility charges cannot be ta...

June 7, 2024 264 Views 0 comment Print

National Faceless Assessment Centre was Prescribed Income tax Authority for issuance of notice u/s 143(2)

Income Tax : Assessee was a commercial bank having its head office in France and had 8 branches in India. Assessee was involved in normal banki...

June 6, 2024 1227 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 1596 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 792 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 588 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 2124 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 4113 Views 0 comment Print


CBDT releases MLI synthesised text for India- Malta tax treaties

March 19, 2020 900 Views 0 comment Print

CBDT has released the synthesised text for India-Malta tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAX TREATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA […]

CBDT releases MLI synthesised text for India-Luxembourg tax treaty

March 19, 2020 1314 Views 0 comment Print

MLI synthesised text for India-Luxembourg tax treaty-This document was prepared jointly by the Competent Authorities of India and Luxembourg and represents their shared understanding of the modifications made to the Agreement by the MLI.

Agreement between India & Brunei for Exchange of Information notified

March 17, 2020 468 Views 0 comment Print

The Agreement between the Government of the Republic of India and the Government of Brunei Darussalam for the exchange of information and assistance in collection with respect of taxes (hereinafter referred to as the Agreement), was signed in New Delhi, India on 28th of February, 2019. The Agreement has been notified in the Gazette of India (Extraordinary) on 9th of March 2020.

Alignment of DTAAs With Multilateral Instrument (MLI)

March 12, 2020 7623 Views 0 comment Print

Alignment of Double Taxation Avoidance Agreements (DTAAs) With Multilateral Instrument (MLI) Background [Section 90 and 90A] Section 90 of the Act empowers the Central Government to enter into DTAAs with foreign countries or specified territories inter alia for avoidance of double taxation of income under the laws of both, India and that foreign country or […]

CBDT notifies DTAA with Brunei Darussalam

March 4, 2020 1473 Views 0 comment Print

MINISTRY OF FINANCE (Department of Revenue) Notification No. 14/2020  New Delhi, the 4th March, 2020 S.O. 1009(E).—Whereas, an Agreement between the Government of the Republic of India and the Government of Brunei Darussalam for the exchange of information and assistance in collection with respect of taxes (hereinafter referred to as the said Agreement) as set […]

Cabinet approves amendment in DTAA with Sri Lanka

February 12, 2020 1524 Views 0 comment Print

Press Information Bureau Government of India Cabinet 12-February-2020 Cabinet approves protocol amending the Agreement between India and Sri Lanka for avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income The Union Cabinet, chaired by the Prime Minister Shri Narendra Modi, has approved the Signing and Ratification of the […]

DTAA : Fees for Technical Services

February 11, 2020 22455 Views 0 comment Print

The absence of the provision in the DTAA is not an omission but is a deliberate mutual agreement between the Contracting States not to recognize/classify any income as Fees for Technical Services for taxation.

Aligning purpose of entering into DTAA with Multilateral Instrument (MLI)

February 3, 2020 1845 Views 0 comment Print

Aligning purpose of entering into DTAA with Multilateral Instrument (MLI) Section 90 of the Act empowers the Central Government to enter into agreement with foreign countries or specified territories (commonly known as DTAAs) for,- (a) granting relief in respect of — (i) income on which tax has been paid both, in India and that foreign […]

How NRIs can avoid Double Taxation?

January 2, 2020 7602 Views 0 comment Print

To avoid paying tax on same income twice, one can use the provisions of the Double Taxation Avoidance Agreement (DTAA), a tax treaty India has signed with many countries.

Section 206AA not override provisions of section 90(2)

December 20, 2019 2091 Views 0 comment Print

Section 206AA does not override provisions of section 90(2) and in case of payment made to non-resident, assessee correctly applied rate of tax prescribed under concerned DTAAs and not as per section 206AA because provisions of the DTAAs were more beneficial and DTAA acquired primacy in such case.

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