Finance : Discover essential financial steps and tax tips for NRIs, including converting accounts, trading restrictions, and leveraging DTAA...
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 : 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 Delhi held that the condition of make available was not satisfied for services when provided by assessee did not enabled the ...
Income Tax : ITAT Pune held that the DTAA does not get triggered at all when a domestic company pays DDT u/s. 115O of the Income Tax Act. In nu...
Income Tax : Delhi High Court held that initiation of reassessment based on entirely new or previously undisclosed material or reasoning depriv...
Income Tax : Understand the Ahmedabad ITAT ruling that payments for certification services by foreign entities are not taxable in India without...
Income Tax : ITAT Chennai restored the matter back to the file of AO for re-adjudication as additional ground raised by the assessee in appeal ...
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...
Liechtenstein has declined help in India’s quest for suspected black money trail to the small but rich European country bordering Switzerland, citing absence of a bilateral treaty for such information exchange. The Indian government is facing intens
The revised tax treaty between India and Switzerland, to enable access to Swiss accounts of tax evaders, seems to have hit bureaucratic hurdle as the two governments are yet to notify each other on the required legal and procedural approvals. As per
Reimbursable expenditure and the fee payable for technical services under DTAA between India and USA- the reimbursable expenditure received by the assessee cannot form part of the total income. – since the development of infrastructure falls within the industrial policy of Government of India specific approval may not be required for claiming exemption u/s. 10(6A) of the Act. – what was reimbursed is the service tax paid by the assessee to the Government account. therefore, such an amount cannot form part of technical fee. In other words, it cannot be treated as trading receipt. In view of the above, in our opinion, the reimbursement of service tax cannot form part of the total income of the assessee. – fee received by the assessee towards technical services / consultancy would fall under Article 12 and not under Article 7. Therefore, tax has to be levied only at 15% and not at 20%. – there is no liability to pay the advance tax wherever the tax was deducted at source. Therefore, interest was not chargeable u/s. 234B of the Act.
The ITAT held that the payments for services rendered with regard to reassembling and recommissioning of machinery in India under the Indian Tax Laws (ITL) and the India-Italy Double Taxation Avoidance Agreement (DTAA), would be excluded from fees for technical services (FTS) under the DTAA since the same were in the nature of business profits.
The Finance Ministry has begun its maiden investigation into over 100 offshore “financial structuring deals” undertaken by Indian business entities in foreign tax havens to allegedly evade the taxman’s net.
The government’s official auditor, Comptroller and Auditor General (CAG), has mooted lower corporate taxes to stop many non-resident firms from misusing the Double Taxation Avoidance Agreements (DTAAs) on account of higher levies in India.
Ruling allows the non-resident assessees to toggle between the DTAA and the Act. The logic of the decision is also in consonance with the provisions of the section 90(2) of the Act which allows the non-residents to be governed by the provisions of the DTAA or Act, whichever is beneficial to them.
If a foreign company pays interest on loan for carrying out operations in India it will be allowed tax exemption under the Income Tax Act, 1961, a tax tribunal has ruled. This has put to rest uncertainties on application of Thin Capitalisation rules
Seeking the help of a friendly official or agent of a foreign bank to open a bank account overseas may not be a good idea as tax sleuths have their eyes on them and could soon be knocking at your doors.Income tax sleuths are keeping a close watch on
Commission paid to agents for services rendered outside India is not chargeable to tax in India and there is no obligation to deduct tax u/s 195. As Agent was not a performer, his income was not covered under Article 18 of the DTAA but was covered by Article 7 and as the services were rendered outside India and there was no PE, the same was not assessable to tax in India.
