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...
Though erstwhile rules 44G and 44H were in existence for a number of years, detailed information regarding MAP processes and guidance on issues related to such processes were not available in a comprehensive and consolidated manner.
The issue under consideration is whether income tax levied on revenue received from IDC agreement, management agreement, and referral agreement as per the India-Singapore DTAA?
A tax haven is a country where taxes are levied at extremely low rates. One country’s tax laws and rules can have an effect on other countries and their economies. Most multinationals operating in developing countries use tax havens. These tax havens often prove to be a way for multinational companies to avoid taxes. More […]
whether the office which is established merely for the sake of communication is covered under the character of Permanent Establishment (PE) under India-Korea DTAA?
In McDowell it was held that if a transaction was carried with an intention to avoid taxes it was up to the judiciary to decide whether the same ought to be regarded. In other words, the duty to decide the validity of the transaction was left to the court.
Computation of Foreign Tax Credit (‘FTC’) in case ofassessee’s with cross border payments has been a major hassle for tax professionals. Absence of well-defined set of rules, coupled with few judicial precedents had resulted in diversified practices. The Central Board of Direct Taxes (‘CBDT’) by Income-tax (18th Amendment) Rules, 2016
The issue under consideration is whether as per India-Mauritius DTAA, Interest Income from Foreign Currency loan and Securities would be eligible to tax in India?
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.
