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Income Tax - Everyone is conversant with the proverb ‘Old wine in new bottles‘. On similar lines, the Finance Act, 2020 shifts the incidence of taxation of dividends in the hands of shareholders by abolishing the DDT regime. Under the new regime (effective 1 April 2020), the dividends earned by foreign shareholders are usually subject ...
Read MoreIncome Tax - Acquisition And Transfer of Immovable Property In India: FEMA and International Taxation Perspective ACQUISITION AND TRANSFER OF IMMOVABLE PROPERTY – A NRI or an OCI may acquire immovable property in India other than an agricultural land or farm house or plantation property. POI as a category is no longer eligible to acquire immovab...
Read MoreIncome Tax - Withholding taxes u/s 195 in respect of transactions with Non-Residents has always been a bone of contention between Assessee and tax authorities. Though liability for deduction of TDS is clear in respect of some transactions like royalties, fees for technical services, interest etc., ...
Read MoreIncome Tax - Taxation of cross border e-commerce transactions has been a challenge for the whole world, including India due to location of the supplier, absence of physical presence, characterizing the nature of transaction (goods or service), administrative challenges in tracking and collecting taxes and taxing jurisdiction....
Read MoreIncome Tax - Double Tax Avoidance Treaty India-Singapore The Double Taxation Avoidance Agreement is a tax accord between two countries to avoid taxing of same income by two countries levying their own tax. Double Taxation unjustly penalizes income flow between the countries and thereby discourages trade & commerce between the countries. To mitigat...
Read MoreIncome Tax - Income Tax Department designates Income tax Authority before whom particulars of parent entity and alternate reporting entity to file Country-by-Country Report would be notified...
Read MoreIncome Tax - CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SLOVAK REPUBLIC AGREEMENT FOR AVOIDANCE OF DOUBLE TAXATION AND PREVENTION OF FISCAL EVASION WITH – SLOVAK REPUBLIC Whereas a Agreement between the Government of th...
Read MoreIncome Tax - CBDT has released the synthesised text for India-Poland tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SYNTHESISED TEXT OF THE MLI AND THE CONVENTION BETWEEN THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THE REPUBLIC OF POLAND FOR THE AVOIDANCE OF DOUBLE TAXATION AND ...
Read MoreIncome Tax - CBDT has released the synthesised text for India-Australia tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. AUSTRALIA SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAXT REATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN ...
Read MoreIncome Tax - CBDT has released the synthesised text for India-Singapore tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAX TREATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN THE GOVERNME...
Read MoreOT Africa Line Limited (now known as Delmas UK Limited) Vs DDIT-nternational Taxation (ITAT Mumbai) - Whether the agent in India was a ‘Dependent Agent’ constituting a permanent establishment (PE) and the appellant was, therefore, liable to be taxed as per India UK DTAA?...
Read MoreMarriot International Inc. Vs DDIT- International Taxation (ITAT Mumbai) - Marriot International Inc. Vs DDIT-International Taxation (ITAT Mumbai) In the instant case, the assessee has undertaken the job of marketing the “Marriott / Rennaisance” brands. There is no doubt that the assessee company belongs to Marriott group. Further the claim of the assessee that it was ...
Read MoreSPX India Pvt. Ltd. Vs CIT (ITAT Delhi) - SPX India Pvt. Ltd. Vs CIT (ITAT Delhi) Tax was required to be deducted at source on share of ISO audit expenses paid to foreign parent company, as element of income was embedded in receipt of auditor. FULL TEXT OF THE ITAT JUDGEMENT Assessee is in appeal before us against the order of ld. CIT [&h...
Read MoreBureau Veritas-Indian Division Vs ADIT (ITAT Mumbai) - Bureau Veritas-Indian Division Vs ADIT (ITAT Mumbai) Technical expenses allocated by head office to assessee-Indian division was in nature of reimbursement of technical expenses to head office and not on account of any specific technical services having been ‘made available’ and, therefo...
Read MoreITO Vs Vishinda Diamonds (ITAT Mumbai) - ITO Vs Vishinda Diamonds (ITAT Mumbai) Sister concern made purchases of rough diamonds on behalf of assessee. Sister concern made payment of core service charges to vendor after deducting tax at rate of 15 per cent as per article 13 of the India-UK DTAA. Assessee reimbursed expenses to sister concer...
Read MoreCircular No. 11/2020-Income Tax / Release ID: 1622386 dated 09/05/2020 - (08/05/2020) - CBDT issues Circular No. 11 of 2020 and excluded period of forced stay in India from 22nd March, 2020 to 31st March, 2020 in computation of residential status in India for Financial Year 2019-20. Circular No. 11 of 2020 F. No. 370142/18/2020-TPI, Government of India Ministry of Finance Department of...
Read MoreNotification No. 22/2020-Income Tax /F.No. 505/01/1982-FTD-I (Pt.) [S.O. 1370(E).] - (24/04/2020) - Protocol Between The Government Of The Republic Of India And The Government Of The Republic Of Austria Amending The Convention For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income, Which Was Signed At Vienna On 8 November, 1999...
Read MoreNA - (17/03/2020) - The Agreement between the Government of the Republic of India and the Government of Brunei Darussalam for the exchange of information and assistance in collection with respect of taxes (hereinafter referred to as the Agreement), was signed in New Delhi, India on 28th of February, 2019. The Agreement...
Read MoreNA - (12/02/2020) - Press Information Bureau Government of India Cabinet 12-February-2020 Cabinet approves protocol amending the Agreement between India and Sri Lanka for avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income The Union Cabinet, chaired by the Prime Minister Sh...
Read MoreNotification No. 54/2019-Income Tax [S.O. 2562(E)] - (17/07/2019) - Protocol amending the Agreement between the Government of the Republic of India and the Government of the People’s Republic of China for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and the Protocol thereto Signed at New Delhi on 18th July, ...
Read MoreOT Africa Line Limited (now known as Delmas UK Limited) Vs DDIT-nternational Taxation (ITAT Mumbai) -
Marriot International Inc. Vs DDIT- International Taxation (ITAT Mumbai) -
SPX India Pvt. Ltd. Vs CIT (ITAT Delhi) -
