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...
Highlights how the Court ruled that consistent operational control and strategic oversight in India can establish a Fixed Place PE under the DTAA, even without exclusive offices. Key takeaway: substance and economic activity override formal ownership.
After examining the step-wise rework operations, the Tribunal found no specialized skill or scientific process involved. It upheld the deletion of the ₹4.81-crore disallowance since the payments did not attract TDS under FTS provisions.
ITAT Delhi held that reimbursements for seconded employees’ salaries cannot be taxed as technical services, as a genuine employer-employee relationship existed with Indian entities. The ruling confirms that taxed salary payments cannot be recharacterized as FTS.
The Supreme Court ruled that TDS on payments to non-residents cannot exceed treaty-specified rates, even if PAN is not provided, ensuring DTAA provisions prevail over Section 206AA.
The Tribunal held that delivery order charges are directly connected to air-cargo transportation and fall within Article 8 of the India–UK DTAA. The ruling confirms such receipts form part of international traffic income and are not taxable in India.
Supreme Court dismissed SLPs, confirming that DTAA rates override Section 206AA for non-residents without PAN. The case follows the Air India ratio, providing legal finality on TDS obligations.
ITAT held that subscription fees received by a global e-commerce platform from Indian customers are not taxable as Fee for Technical Services (FTS). Standard automated digital facilities without human intervention cannot be treated as FTS under Section 9(1)(vii) and India–Singapore DTAA.
Get a comprehensive overview of dividend taxation after the shift to the classical system. Covers TDS obligations, tax rates, DTAA benefits, Section 80M relief, and new rules applicable to IFSC and foreign investors.
A clear guide on how US dividends are taxed under the India–US DTAA. Key takeaway: US withholding is capped at 25%, but India taxes dividends fully with FTC relief.
India’s upcoming tax law changes could redefine resident status for high-income diaspora. Learn how this reform increases global income tax risks and affects treaty benefits for overseas investors.
