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...
ITAT Bangalore held that unless the non-resident, who is engaged in sale of online advertisement space, has a PE in India, no portion of receipts earned by it from sale of online advertisement space in India can be brought to tax in India as Act read with the relevant DTAA.
Kanagaraj Shanmugam Vs ITO (ITAT Chennai) From the fact it emerges that the assessee has stayed in India for 63 days during this year and his status, as per law, is non-resident. The assessee has worked in India for 21 days and offered proportionate salary to that extent to tax. For remaining period, the work […]
ITAT Mumbai held that freight charges received from transportation of cargo through feeder vessels being part of shipping income in International Traffic is covered under Article–9(1) of the India–France Tax Treaty and hence not taxable in India.
ITAT Kolkata held that interest on income tax refund is a ‘debt claim’ payable by the Revenue in terms of Article 12(3)(a) of the India-Italy Treaty and thus such interest is not taxable and no TDS ought to be done by the AO.
Toshiba JSW Power Systems Private Limited Vs DCIT (ITAT Chennai) The AO had held that payment made by the assessee to non-resident towards cost of salary of seconded employees is fees for technical services as per section 9(1)(vii) of the Act and also as per Article 12(4) of India & Japan DTAA and held to […]
ACIT Vs IQOR India Services Pvt. Ltd. (ITAT Delhi) Assessee submitted that there are a number of decisions of the co–ordinate Benches, wherein, with reference to India-Philippines DTAA, it has been held that, even, in absence of FTS clause, the income would be governed under the other provisions of DTAA, hence, has to be treated […]
Explore the impact of residence status on taxation for Indian citizens abroad, NRIs, PIOs, and OCIs. Understand the rules, exemptions, and tax implications.
TDS credit was allowed as the commission income was not managerial service under India Germany Double Taxation Avoidance Agreement (DTAA).
Article explains What is Double Taxation Avoidance Agreement (DTAA), and how DTAA helps, types of relief under DTAA, Benefits of DTAA, How to claim DTAA benefits in India and What are the documents required for an NRI to claim DTAA benefit. What if you currently reside in the UK, have invested in India, and are […]
Income from supply of CAS and middleware products to indian customers, does not fall under ‘royalty’ as defined under Section 9(l)(vi) of Income Tax Act, 1961 and Article 12(3) of India- Swiss DTAA.
