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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...
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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...
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The Union Cabinet, chaired by the Prime Minister Shri Narendra Modi, has approved the signing and ratification of the agreement between India and Seychelles for exchange of information with respect to taxes. The Agreement will stimulate the flow of exchange of information between India and Seychelles for tax purposes, which will help curb tax evasion […]
In the present case services were provided by the non-resident individuals so article 15 was applicable but the pre-requisite condition that the each non-resident individual had to be present in India for more than 90 days which was not ascertained.
Section 206AA has been brought into Act from 1.4.2010. This section talks about furnishing of Permanent Account number (PAN) by any person entitled to receive any sum or income or amount on which tax is deductible under Chapter XVIIB. This provision cast a obligation on any person receiving an income to furnish PAN to deductor, failing on which tax shall be deducted at the higher of following;
Lump-sum payments are covered under the term royalty. The agreement postulated grant of permission to use or right to use intellectual property rights or knowhow and it is not a case of outright sale.
One of the decisions rendered by the Bangalore ITAT in the year 2012 relating to Section 206AA, in case of Bosch Ltd. (141 ITD 38) confirming its ability to Override the provisions of the Entire Income Tax Act. However as regards dispute that was there before the Hon. bench was only with regard to Section 139A(8)(d) read with Rule 114C and 206AA.
Since the income of CGS International and Marble Arts & Crafts can only be classified under Article 14 or Article 22 of the DTAA – both of which provide that the income shall be taxable in the State of residence (UAE)–the issue as to whether the services provided by the two UAE entities fall within the scope of professional services under Article 14 is irrelevant to the outcome of this case.
Bangalore ITAT, A Bench has in the case of IBM India Private Ltd., v ITO (TDS) held that Tax deduction at source / Tax collection at source [TAS] Provisions are attracted even if the provision is made in the books of account to measure the economic performance of the entity irrespective of whether the exact amount and the payee is determined or not.
Notification No. 45/2015 – Income Tax Dated- 22nd May, 2015 Central Government hereby directs that all the provisions of the said Protocol between the Government of the Republic of India and the Government of the Kingdom of Denmark as set out in the Annexure hereto, shall be given effect to in the Union of India with effect from the first day of February, 2015.
Revised Agreement between India and the Republic of Korea for the Avoidance of Double Taxation and Prevention of fiscal evasion taxes on income The Union Cabinet, chaired by the Prime Minister Shri Narendra Modi, has given its approval for revising the Double Taxation Avoidance Convention (DTAC) which was signed in 1985, between India and the […]
It has come to the notice of the Board that several Foreign Institutional Investors receiving income from transactions in securities claim such income as exempt from tax under the Income Tax Act, 1961(‘the Act’) by availing benefit provided in the Double Taxation Avoidance Agreements(‘DTAAs’) signed between India and their respective countries of residence.
