Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...
Income Tax : Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping...
Income Tax : Understanding taxation for NRIs: Learn about residential status, taxable income, deductions, and the importance of Double Taxation...
Income Tax : Explore the nexus between tax avoidance and inequality in India. Learn how legal loopholes deepen economic divides and discover st...
Income Tax : CIT – International Taxation Vs. ESPN Star Sports Mauritius S.N.C ET Compagnie (Delhi High Court) The Delhi HC affirms the o...
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 : ITAT Indore rules in Asha Rani Pandya Vs DCIT/ACIT that filing Form 67 for claiming Foreign Tax Credit (FTC) is a directory requir...
Income Tax : Read the full text of the ITAT Delhi order on Cricket Australia vs. ACIT (International Taxation). Analysis includes why license f...
Income Tax : For income to be taxable under FTS, there must be a direct enablement or transfer of skills or knowledge, which mere advisory or c...
Income Tax : Read the full text of the ITAT Delhi order in Suchi Agrawal vs. ITO, where the requirement of Form-67 for foreign tax credit was d...
Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...
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...
Income Tax : The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (part...
Enabling the Board to notify rules for giving foreign tax credit Sub-section (1) of section 91 of the Income-tax Act provides for relief in respect of income-tax on the income which is taxed in India as well as in the country with which there is no Double Taxation Avoidance Agreement (DTAA). It provides that an […]
The provisions of section 5 of the Act provide for scope of total income for the purposes of its chargeability to tax. In case of a non-resident person, the chargeability of income in India is on the basis of source rule under which certain categories of income are deemed to accrue or arise in India. […]
Birla Corporation Limited Vs ACIT (ITAT Jabalpur) Installation, commissioning or assembling services being part of composite supply contract covered by specific article on PE of DTAA and not general article on FTS. Facts of the case: Birla Corporation Ltd. (taxpayer), an Indian company is engaged in the business of manufacturing and selling cement. During the […]
Notification No.47/2014-Income Tax Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961), the Central Government hereby directs that all the provisions of the said Protocol amending the agreements between the Government of the Republic of India and the Government of Polish People’s Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, as set out in the Annexure hereto, shall be given effect to in the Union of India with effect from the first day of April, 2015, being the first day of the fiscal year next following the year in which the Protocol enters into force.
Notification No. 44/2014 Income Tax The Government of the Republic of India and the Republic of Colombia, desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and with a view to promoting economic cooperation between the two countries, have-agreed as follows:
Notification No. 42/2014-Income Tax S.O. (E).- Whereas, an Agreement between the Government of the Republic of India and the Royal Government of Bhutan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income was signed in India on the 4th day of March, 2013 (hereinafter referred to as the Agreement)
CA Paras Mehra Mr Ashish Ranjan, developer, started his business in Hong Kong. Since he was good at marketing, his business soon started generating profits. Ashish, through his Hong Kong Company expands his business in India and incorporates a company which is fully controlled by Hong Kong Company. Ashish, because his business was doing well, […]
Assessee is an employee of a Canadian Company. He went to Canada on 1st March, 2013 and he came back to India on 2nd October, 2013. Then on 17th November, 2013 he again went to Canada and came back on 22nd November, 2013. Assessee was paid salary outside India and that was also in a Bank Account which is also operated outside India. It also to be noted that during the period of stay in India, neither salary was paid in India nor any other payment was received by the employee from the company in India.
Notification No. 34/2014-Income Tax Whereas, the Agreement and the Protocol (hereinafter referred to as the said Agreement and the Protocol) was entered into between the Government of the Republic of India and the Government of Malta, for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Notification No. 30/2014-Income Tax Whereas, an agreement (hereinafter referred to as the said agreement) between the Government of the Republic of India and the Government of the Principality of Liechtenstein, for the exchange of information on tax matters was signed at Berne, Switzerland on the 28th day of March, 2013
