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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 546 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 786 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 6216 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 438 Views 0 comment Print

Payments made under distribution agreement not taxable in India: Delhi HC

Income Tax : CIT – International Taxation Vs. ESPN Star Sports Mauritius S.N.C ET Compagnie (Delhi High Court) The Delhi HC affirms the o...

March 23, 2024 1005 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 198 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 702 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 798 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 708 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 369 Views 0 comment Print


Latest Judiciary


Filing Form 67 for Foreign Tax Credit is Directory, Not Mandatory: ITAT Indore

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...

July 15, 2024 435 Views 0 comment Print

Cricket Australia vs. ACIT: Live Transmission Fee Not Taxable as Royalty

Income Tax : Read the full text of the ITAT Delhi order on Cricket Australia vs. ACIT (International Taxation). Analysis includes why license f...

July 9, 2024 120 Views 0 comment Print

Income Taxable Under FTS Requires Direct Enablement or Skill Transfer, Advisory Services Not Sufficient Without PE Connection

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...

July 8, 2024 267 Views 0 comment Print

Form 67 submission Not Mandatory for Availing  Foreign Tax Credit: ITAT Delhi

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...

June 24, 2024 483 Views 0 comment Print

Delhi ITAT Rules No Tax on Technical Services to AE Without PE in India

Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...

June 20, 2024 447 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 1989 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 828 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 594 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 2298 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 4191 Views 0 comment Print


United Nations Handbook on Administration of Double Tax Treaties

December 1, 2013 1187 Views 0 comment Print

Tax treaties play a key role in the context of international coop¬eration in tax matters. On the one hand, they encourage international investment and, consequently, global economic growth, by reducing or eliminating international double taxation over cross-border income. On the other hand, they enhance cooperation among tax administra¬tions, especially in tackling international tax evasion.

Mauritius Route : A Long Lasting Story

November 13, 2013 5537 Views 0 comment Print

Since the inception of its Financial Services sector, Mauritius has taken all appropriate steps to safeguard the credibility of its jurisdiction. Mauritius has a stringent legal and regulatory framework recognized by the International Monetary Fund,

India signs DTAA with Latvia

September 19, 2013 1735 Views 0 comment Print

An Agreement and Agreed Note Signed Between India and Latvia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (DTAA) The Government of India today signed an Agreement and the Agreed Note for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect […]

Amendment in Agreement For Avoidance Of Double Taxation And Prevention Of Fiscal Evasion With Sweden

August 14, 2013 661 Views 0 comment Print

Notification No. 63/2013 – Income Tax S.O.2459(E) – Whereas a Protocol (hereinafter referred to as the said Protocol) amending the convention between the Government of the Republic of India and the Government of the Kingdom of Sweden for the avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on Income and on Capital, which was signed at New Delhi on the 24th June, 1997, was signed on the 7th February, 2013 in Stockholm ;

India signs Protocol amending India – Morocco Double Taxation Avoidance Convention (DTAC)

August 8, 2013 444 Views 0 comment Print

India signed a Protocol amending the India – Morocco Double Taxation Avoidance Convention (DTAC) in New Delhi today. The Protocol was signed by Dr Sudha Sharma, Chairperson, Central Board of Direct Taxes on behalf of Government of India and H.E. Mr. Larbi Reffouh, Ambassador of the Kingdom of Morocco to India on behalf of Government of the Kingdom of Morocco.

Sanofi Pasteur case: a comprehensive analysis

August 6, 2013 1994 Views 0 comment Print

This is a case before the Division Bench of Andhra Pradesh High Court whereby the petitioner has challenged the decision of the Authority of Advanced Ruling. The AAR held the petitioner to be an assessee in default under Section 201(1) of the Income Tax Act.

India Enters in Comprehensive DTAA with Uruguay effective from 21.06.2013

July 5, 2013 3640 Views 0 comment Print

Notification No. 53/2013 – Income Tax Whereas, an Agreement between the Government of the Republic of India and the Government of the Oriental Republic of Uruguay for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and on capital was signed in India on the 8th day of September, 2011 (hereinafter referred to as the Agreement);

India-Japan DTAA – taxability of a sum received from onshore activities to tax in India

June 26, 2013 6358 Views 0 comment Print

The assessee is a company incorporated in and tax resident of Japan engaged in manufacturing of heavy machinery, providing technology oriented products and services to industrial, private and public sectors.

Circuitous amendments of section 90/90A, relating to Tax Residency Certificate

May 31, 2013 40590 Views 1 comment Print

There is a peculiar history regarding the amendments of section 90 of the Income-Tax Act, 1961 (the Act), by the Finance Act, 2012 and the Finance Act, 2013, in respect of the requirement of Tax Residency Certificate (TRC) to be obtained by an assessee, in order to avail of the benefit of Double Taxation Avoidance Agreement (DTAA) between India and the country of his residence.

Requirement of TRC to contain prescribed particulars to be dispensed with

May 3, 2013 2301 Views 0 comment Print

Sub-section (4) of 90 and 90A provides that treaty benefit will not be available to any Non Resident unless he furnishes TRC from the Government of his country of residence containing such particulars as may be prescribed. The Finance Bill, 2013 had proposed to insert sub-section (5) in sections 90 and 90A to provide that […]

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