Income Tax : Switzerland halts the unilateral application of the MFN clause under its tax treaty with India from 2025, following the Indian Sup...
Income Tax : Learn how international transactions are taxed under India’s Income Tax Act, including DTAAs, transfer pricing, TDS provisions, ...
Income Tax : Switzerland suspends the MFN clause with India following a Supreme Court ruling in the Nestle case, impacting dividend tax rates f...
Income Tax : Explore the tax implications for IPL players, including income tax for Indian and overseas players, TDS rates, and the role of DTA...
Income Tax : Explore the India-Mauritius DTAA's impact, treaty shopping challenges, and recent amendments aimed at preventing tax abuse and fos...
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 : Karnataka High Court held that TDS is not deductible on payment to non-residents for advertisements in several social medias like ...
Income Tax : ITAT Mumbai held that that reimbursement of expenses at cost is not taxable as fees for technical services since there is no eleme...
Income Tax : Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidia...
Income Tax : ITAT Delhi rules IT support payments to CPP UK not taxable as fees for technical services due to failure of ‘make available’ t...
Income Tax : ITAT Mumbai ruled on TVF Fund Ltd’s appeal regarding tax loss set-off under DTAA. Key issues include carry-forward losses, taxab...
Income Tax : Circular No. 01/2025 outlines the application of the Principal Purpose Test (PPT) under India's Double Taxation Avoidance Agreemen...
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...
Data Transmission Services did not amount to royalty in terms of Article 12 of the Indo-Thai Double Taxation Avoidance Agreement.
TDS liability on payment to non-residents which is exempt under DTAA The Supreme Court in its recent judgment in the case of PILCOM vs CIT in SLP (CIVIL) No.7315 of 2019 has created a controversy on the withholding tax provision on the payment to be made to Non-resident. The recent judgement of Supreme Court has […]
The lack of an express legislation has always embarked a debate surrounding the issue of double taxation. Taxes are a compulsory imposition but by virtue of the constitution of India, taxes can only be imposed by the force of law. The presence of Article 265 of the constitution gives a statutory recognition to taxability.
Aspect Software Inc Vs DCIT (ITAT Delhi) Consideration received by the Assessee for supply of product along with license of software to End user is not royalty under Article 12 of the Tax Treaty. Even where the software is separately licensed without supply of hardware to the end users (i.e. eight out of 63 customers), […]
DCIT Vs Bharath Fritz Werner Ltd. (ITAT Bangalore) At the time of hearing it was not disputed that the issue raised by the revenue in its appeals are already decided by a Special Bench of ITAT, Hyderabad. The issue regarding the applicability of provisions of section 206AA of the Act, in cases of tax to […]
The issue which is arising in the present appeal is whether there is DAPE. The Assessing Officer has alleged the existence of DAPE on account of alleged marketing activities undertaken by Indian entity on behalf of the assessee company.
Corporate India today serves global needs and brings in overseas income which is chargeable to Indian tax net as a resident of India. Flip side of this paves way for claim for taxes paid at foreign jurisdiction based on the source of income.
The issue under consideration is whether the contention of AO is correct in holding that the income from sale of shrink-wrapped software is taxable in India as a royalty?
The issue under consideration is whether it is correct to treat the Subscription fees received from subscribers on sale of online product as Royalty income under Income Tax Act?
Whether the agent in India was a ‘Dependent Agent’ constituting a permanent establishment (PE) and the appellant was, therefore, liable to be taxed as per India UK DTAA?
