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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 645 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 5604 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 387 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 939 Views 0 comment Print

Key Provisions and Implications of India-USA Tax Treaty

Income Tax : Explore the India-USA Tax Treaty, its provisions, implications, and how it prevents double taxation. Learn about residency, taxati...

March 18, 2024 2835 Views 1 comment Print


Latest News


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 627 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 792 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 699 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 360 Views 0 comment Print

CBDT releases MLI synthesised text for India-Poland tax treaty

Income Tax : CBDT has released the synthesised text for India-Poland tax treaty. It represents their shared understanding of the modifications ...

March 19, 2020 657 Views 0 comment Print


Latest Judiciary


Section 270AA Penalty Immunity Application Cannot Be Rejected on Insufficient Grounds or Vague SCNs

Income Tax : Delhi High Court judgment on GE Capital vs. DCIT, distinguishing under-reporting and misreporting as separate offenses, resulting ...

June 13, 2024 219 Views 0 comment Print

Guarantee Commission Charges taxable in India as “other income” under Article 23(3) of Indo-UK DTAA

Income Tax : Guarantee commission charges received by a foreign parent company from its Indian subsidiaries were taxable in India, not as inter...

June 12, 2024 288 Views 0 comment Print

Subsidiary would only be deemed a PE if it satisfies specific tests outlined in DTAA

Income Tax : Delhi High Court quashes reassessment notices by DCIT after TPO settles arm's length remuneration issue. Detailed analysis of Prog...

June 9, 2024 330 Views 0 comment Print

In absence of DTAA No tax on payments received by non-resident for IUC from Indian company

Income Tax : ITAT Bangalore ruled that payments received by a non-resident from an Indian company for interconnect utility charges cannot be ta...

June 7, 2024 264 Views 0 comment Print

National Faceless Assessment Centre was Prescribed Income tax Authority for issuance of notice u/s 143(2)

Income Tax : Assessee was a commercial bank having its head office in France and had 8 branches in India. Assessee was involved in normal banki...

June 6, 2024 1227 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 1596 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 792 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 588 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 2124 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 4113 Views 0 comment Print


Article 13(4) of India-Mauritius DTAA exempts sale of shares acquired prior to 1st April 2017

February 10, 2024 825 Views 0 comment Print

ITAT Mumbai held that benefit of Article 13(4) of India Mauritius tax Treaty duly available to Mauritius registered assessee, having Tax Residency Certificate, for sale of shares which were acquired prior to 1st April 2017.

Obligation of Foreign Company to file Income Tax return of India

February 8, 2024 3882 Views 0 comment Print

Explore the legal framework, exemptions, and compliance challenges surrounding the obligation of foreign companies to file income tax returns in India. Learn about transfer pricing requirements and the implications of non-compliance.

GSMA vs DCIT: ITAT Rules No Royalty on IMEI Database Fees

February 8, 2024 285 Views 0 comment Print

ITAT Delhi rules in favor of GSMA Limited. Administrative fees for IMEI database access not deemed royalty. Detailed analysis of the order and tax implications.

CBDT notifies Tax Information Exchange Agreement: India-Samoa

February 7, 2024 792 Views 0 comment Print

Explore implications of Notification No. 21/2024 from Indias Ministry of Finance regarding the tax information exchange pact with Samoa. Learn more here.

Management Support Fees Not FTS under India-Singapore DTAA: ITAT Delhi

February 2, 2024 453 Views 0 comment Print

Read the detailed analysis of ITAT Delhi’s order in Cameron (Singapore) vs ACIT case. Learn why management support fees are not considered FTS under India-Singapore DTAA. Get insights on grounds, TDS credit, interest, and penalty.

India-Korea DTAA Article 15(1): Korean Resident’s Salary for Services Outside India Not Taxable  

January 21, 2024 657 Views 0 comment Print

ITAT Delhi rules in Amit Laroya vs ACIT case, stating salary of a Korean resident for services outside India is not taxable in India under Article 15(1) of India-Korea DTAA.

Sports Broadcasting Fees for Live Feed Not Taxable as Royalty: Delhi High Court

January 21, 2024 537 Views 0 comment Print

Delhi High Court’s judgment in CIT vs. Fox Network Group Singapore PTE Ltd. clarifies income tax treatment of live transmission fees under Income Tax Act Section 9(1)(vi).

Significant Economic Presence (SEP): Implications for Non-Residents in India

January 20, 2024 1416 Views 0 comment Print

This article sheds light on the concept of Significant Economic Presence (SEP) under Section 9 of the Indian Income Tax Act, 1961, and its implications for non-residents.

Section 115-O Rate Applies for Additional Tax on Dividends to Non-Residents, Not DTAA Rate

January 19, 2024 744 Views 0 comment Print

Explore Sennheiser Electronics India vs Circle – 4 case at ITAT Delhi. Section 115-O rate applies for additional tax on dividends to non-residents, not DTAA rate.

Royalty u/s 9(1)(vi): Broadcasting rights for live event not chargeable to tax as royalty

January 18, 2024 864 Views 0 comment Print

ITAT Delhi held that broadcasting “Live events” does not amount to a work in which copyright subsists i.e., “Live Rights”, is not “copyright” and therefore any payment made thereto can’t be said to be chargeable to tax as royalty under section 9(1)(vi).

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