Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...
Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...
Income Tax : This guide explains how the abolition of DDT shifted the tax burden on dividends from companies to shareholders from 1 April 2020 ...
Income Tax : The guide explains how residents can avoid double taxation through DTAA benefits, Foreign Tax Credit, and Section 91 relief, outli...
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 : 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 : ITAT Delhi held legal services are not FTS under Section 9(1)(vii) and directed partner-wise DTAA examination. FTS addition was de...
Income Tax : ITAT Mumbai allowed deduction of ESOP expenses under Section 37(1) by following Karnataka High Court's ruling in Biocon Ltd. Tribu...
Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...
Income Tax : ITAT Pune held that Foreign Tax Credit cannot be denied merely because Form 67 was filed after the prescribed due date. The Tribun...
Income Tax : The Delhi ITAT ruled that no installation or supervisory PE existed in India as the activities did not exceed the 120-day threshol...
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...
The OECD under BEPS Action Plan 7 reviewed the definition of ‘PE’ with a view to preventing avoidance of payment of tax by circumventing the existing PE definition by way of commissionaire arrangements or fragmentation of business activities.
Under the Income-tax Act, 1961, Education cess and Secondary and Higher education cess are imposed on account of the provisions contained in sub-section (12) of Chapter III of the Annual Finance Act which provides the rates of income-tax.
Central Government hereby notifies that all the provisions of amending Protocol entered into between India and Brazil shall have effect in the Union of India with effect from the 6th day of August, 2017.
CIT Vs. Mitsubishi Corporation India P. Ltd. (Delhi High Court) Due to difference of opinion on below issues between Justices S Muralidhar and Prathiba M Singh, Delhi High Court, has referred the Mitusubishi’s TDS case to Chief Justice for appropriate orders:- (i) Whether the ITAT fell into error in holding that Section 40(a) (i) of […]
Cabinet approves the protocol amending the Agreement between India and Kyrgyz for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income The Union Cabinet chaired by the Prime Minister Shri Narendra Modi has given its approval for the protocol amending the Agreement between India and Kyrgyz Republic […]
Cabinet approves Agreement between India and the Hong Kong Special Administrative Region of China for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income
Agreement between the Government of the Republic of India and the Government of the Government of New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes – Notification No. 93/2017 – Income Tax
S.O. 2826(E).—Whereas the Protocol amending the Agreement, signed at Ha Noi on the 7th day of September, 1994, between the Government of the Republic of India and the Government of the Socialist Republic of Viet Nam for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income
The article primarily deals with the procurements made by the SEZ units from the DTA suppliers and the tax ability thereon. It contains a summarized procedure for availing supplies at zero rate of tax by the SEZ units and also discusses the refund mechanisms available in the hands of the supplier.
The ITAT Mumbai in Citicorp Investment Bank (Singapore) Ltd v. DCIT, held that the sale consideration received by a Singapore based Company on sale of debt instrument is not taxable as capital gain under the Income Tax Act in view of article 13(4) of the India-Singapore Double Taxation Avoidance Agreement (DTAA).
