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DTAA

Latest Articles


Essential Financial Steps and Tax Tips that every NRI’s must not miss

Finance : Discover essential financial steps and tax tips for NRIs, including converting accounts, trading restrictions, and leveraging DTAA...

July 18, 2024 717 Views 0 comment Print

Taxation in Digital Economy: Income Tax provisions in India vis-à-vis Permanent Establishment

Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...

July 13, 2024 660 Views 0 comment Print

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 882 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 6678 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 483 Views 0 comment Print


Latest News


Representation to Simplify & Automate TRC Issue Process for Indian Companies

Income Tax : Explore challenges in TRC applications under DTAA by Indian companies. KSCAA proposes reforms for a simpler, efficient process. Le...

June 22, 2024 234 Views 0 comment Print

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 759 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 816 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 717 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 390 Views 0 comment Print


Latest Judiciary


Condition of ‘make available’ not satisfied hence technical service not taxable: ITAT Delhi

Income Tax : ITAT Delhi held that the condition of make available was not satisfied for services when provided by assessee did not enabled the ...

August 16, 2024 72 Views 0 comment Print

Domestic company paying DDT u/s. 115O doesn’t enter domain of DTAA: ITAT Pune

Income Tax : ITAT Pune held that the DTAA does not get triggered at all when a domestic company pays DDT u/s. 115O of the Income Tax Act. In nu...

August 16, 2024 78 Views 0 comment Print

Reassessment unsustained as based on entirely new reason which deprives assessee’s right to object: Delhi HC

Income Tax : Delhi High Court held that initiation of reassessment based on entirely new or previously undisclosed material or reasoning depriv...

August 12, 2024 192 Views 0 comment Print

No tax on amount paid for certification services rendered by foreign entities in absence of fixed place of business in India

Income Tax : Understand the Ahmedabad ITAT ruling that payments for certification services by foreign entities are not taxable in India without...

August 1, 2024 162 Views 0 comment Print

Additional grounds raised in appeal needs adjudication by lower authority: ITAT Chennai

Income Tax : ITAT Chennai restored the matter back to the file of AO for re-adjudication as additional ground raised by the assessee in appeal ...

July 26, 2024 654 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 2238 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 867 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 609 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 2403 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 4248 Views 0 comment Print


Resolution of more than 100 cases of transfer pricing disputes with USA under MAP-regarding

January 28, 2016 1064 Views 0 comment Print

One of the significant steps taken by Central Board of Direct Taxes to boost investment sentiments among MNCs is the landmark Framework Agreement signed with the Revenue Authorities of USA in January, 2015. This agreement was finalised under the Mutual Agreement Procedure (MAP) provision contained in the India-USA Double Taxation Avoidance Convention (DTAC).

Rates as per DTAA includes all surcharges, addition on account of education cess not sustainable

January 21, 2016 20342 Views 0 comment Print

ITAT Delhi held In the case of OSRAM India Pvt. Ltd. vs. DCIT that Article 2(1) of the India Singapore tax treaty provides that the taxes covered shall include tax and surcharge thereon. Once it is concluded that education cess is nothing but an additional surcharge

Where assessee has dependent agent & fixed place of business in India he is deemed to be PE as per Article 5 (1) of Indo US tax treaty

December 21, 2015 1964 Views 0 comment Print

In the case of Travelport LP USA Vs. DDIT Delhi Bench of ITAT observed that assessee has a dependent agent in form of distributor in India and held that assessee has a business connection in India u/s 9(1) (i) of the act and its income is deemed to accrue or arise in India.

India enters DTAA with Macedonia

December 21, 2015 916 Views 0 comment Print

Notification No. 94/2015 – Income Tax Whereas, an Agreement was entered into between the Government of the Republic of India and the Government of the Republic of Macedonia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income that was signed at Delhi on the 17th December, 2013 as set out in the Annexure to this notification (hereinafter referred to as the said Agreement):

India and Japan signs a Protocol for amending existing Convention for avoidance of double taxation and for prevention of fiscal evasion

December 11, 2015 360 Views 0 comment Print

The Government of India and the Government of Japan signed here today a Protocol for amending the existing Convention for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income. The existing Convention was signed way back in 1989. Dr Hasmukh Adhia, Revenue Secretary signed the protocol on behalf of the Government of India while Mr Kenji Hiramatsu, Ambassador of Japan on behalf of the Government of Japan.

India- Korea sign MOU to suspend tax collection during pendency of MAP

December 10, 2015 789 Views 0 comment Print

A meeting was held on 9th December, 2015 between Indian and Korean delegations headed by Revenue Secretary and Commissioner, National Tax Service, Korea under the Memorandum of Understanding for Mutual Co-operation between the countries. During the meeting, a new Memorandum of Understanding (MoU) on suspension of collection of taxes during pendency of Mutual Agreement Procedure (MAP) was signed.

Amendment in DTAA between India and Turkmenistan

November 5, 2015 666 Views 0 comment Print

The Union Cabinet chaired by the Prime Minister Shri Narendra Modi, has given its approval today for amending the Double Taxation Avoidance Convention (DTAC) signed between India and Turkmenistan in 1997 for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income and on capital, through a Protocol.

Benefits under Indo-Singapore tax treaty cannot be denied where such income have taxed on accrual basis in treaty country

November 1, 2015 1739 Views 0 comment Print

ITAT Rajkot held In the case of GAC Shipping India Pvt. Ltd. vs. ITO – International Taxation that entire freight income of the assessee, which is only from operation of ships in international traffic, is taxable only in Singapore.

Protocol for establishment of the India-Ecuador Joint Economic and Trade Committee (JETCO) signed

October 10, 2015 345 Views 0 comment Print

The Ambassador of Ecuador to India, H.E. Mr. Mentor Villagomez met Ms. Rita Teotia, Commerce Secretary, Government of India on 9th October, 2015 and discussed measures to enhance bilateral trade and investment relations between both the countries. During the year 2014-15, the bilateral trade between the two countries stood at US $ 1290.77 million.

No fresh Income tax notice to Nokia India : CBDT

October 10, 2015 1001 Views 0 comment Print

There have been some reports in the media yesterday and today that the Income tax Department has issued fresh demand notice to Nokia India. These reports are erroneous. An assessment order was passed in the case of Nokia India Pvt Ltd for Assessment Year 2010-11 in August 2015. The tax demand raised by this order was primarily based on issues arising from earlier orders.

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