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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 231 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 2127 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

Avoidance of Double Taxation agreement

January 17, 2024 1161 Views 0 comment Print

Explore the impact of Double Taxation on international business, the role of Double Taxation Avoidance Agreements (DTAA), benefits, and case laws. Learn how to apply DTAA for tax relief

Software Sale Payment Not Royalty under Indo-Singapore DTAA: Delhi HC

January 17, 2024 483 Views 0 comment Print

Delhi High Court upholds ITAT order: Payments received for software sale/supply not considered royalty under India-Singapore Double Taxation Avoidance Agreement (DTAA).

Section 248 Inapplicable to Tax Liability in Dividend Distribution by a Company

January 16, 2024 546 Views 0 comment Print

Explore the Madras High Court’s ruling on Section 248’s inapplicability to dividend declarations. Detailed analysis and implications of the judgment.

Delhi High Court Closes CCD Taxation Appeals, Awaits Supreme Court’s Final Decision

January 16, 2024 567 Views 0 comment Print

Delhi High Court disposes of CIT Vs Zaheer Mauritius appeals, addressing taxability and capital gains nature of Compulsorily Convertible Debentures under India-Mauritius DTAA.

BEPS Principles and MLI Framework in India’s PE Status under DTAA

January 15, 2024 954 Views 0 comment Print

Explore the impact of BEPS principles and MLI framework on India’s Double Taxation Avoidance Agreements (DTAA). Detailed analysis of the India-Singapore DTAA, changes in PE clauses, and post-BEPS amendments.

Receipt in terms of Strategic Oversight Services Agreement cannot be termed as royalty

January 6, 2024 441 Views 0 comment Print

Delhi High Court held that the consideration received in terms of Strategic Oversight Services Agreements (SOSA) cannot be termed as Royalty under Article 12 of the DTAA even if extensive services are rendered which includes access to written knowledge, processes, and commercial information in furtherance of the services.

Exploring The Emerging Areas of International Taxation

January 5, 2024 819 Views 0 comment Print

Explore the dynamic landscape of international taxation, delving into emerging areas like digital companies, cross-border transactions with cryptocurrencies, and the evolving tax landscape for multinational corporations. Stay informed on transfer pricing regulations and ensure compliance for a seamless global business experience.

Form 10F Guide: Tax Treaty Benefits for Non-Resident Receiving Indian Income

January 5, 2024 18486 Views 2 comments Print

Understand Form 10F for non-residents receiving income from India. Learn about electronic filing, recent changes, and the benefits of claiming tax treaty relief with Tax Residency Certificate (TRC).

Decoding Grant Thornton Case: Impact on Cross-Border Transactions

January 4, 2024 915 Views 0 comment Print

Explore Grant Thornton India LLP case, unraveling complex international tax issues. Analysis of arguments, rulings, and broader implications for businesses in cross-border transactions.

No Profit Attribution if Ricardo India’s Commission Adjusted: Delhi HC

January 2, 2024 414 Views 0 comment Print

Explore Delhi High Court’s ruling in CIT vs Ricardo U.K. Limited. No profit attribution if commission paid to Ricardo India is adjusted against PE profit. Detailed analysis and implications.

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