Income Tax : Learn how Indian residents can claim relief from double taxation through DTAA and Section 91. Understand Foreign Tax Credit rules,...
Income Tax : The Supreme Court's ruling on Permanent Establishment (PE) expands taxability for MNEs, holding that "effective control and contin...
Income Tax : Recent ITAT and High Court rulings confirm the Tax Residency Certificate (TRC) is key to claiming DTAA benefits, reinforcing prote...
Income Tax : Understand when NRIs must file Indian income tax returns (ITR), key exemptions, and the impact of residential status (ROR, RNOR, N...
Income Tax : PPT provisions inapplicable in absence of separate notification incorporating MLI provisions into India-Ireland tax treaty Backgro...
Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...
Corporate Law : Learn about CRS and FATCA, how India receives foreign account info, and the disclosure requirements for foreign assets and income ...
Income Tax : From April 2025, foreign taxes withheld must be included in total income for accurate reporting under section 198. Aims to prevent...
Income Tax : Explore challenges in TRC applications under DTAA by Indian companies. KSCAA proposes reforms for a simpler, efficient process. Le...
Income Tax : Appendix-I Declaration of no PE in India Declaration required u/s 9 of Income Tax Act, and for claiming relief under an agreement ...
Income Tax : The Bombay High Court quashed the AAR’s ruling that denied Mauritius DTAA benefits to Bid Services Division (Mauritius) Limited....
Income Tax : Tribunal held that cost-to-cost reimbursements for IT support services do not qualify as Fees for Included Services (FIS) under Ar...
Income Tax : ITAT Delhi ruled that a valid Tax Residency Certificate (TRC) issued by Mauritius is sufficient proof of residency to claim benefi...
Income Tax : ITAT deleted a Rs.54.85 crore tax addition, holding that make available clause of the India's DTAA was not satisfied because routi...
Income Tax : The ITAT Delhi ruled that Marketing & Reservation Contributions (MRC) received by a US-based hotel brand entity from Indian franch...
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 : 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...
Learn how Indian residents can claim relief from double taxation through DTAA and Section 91. Understand Foreign Tax Credit rules, required forms, filing procedures, and eligibility for claiming tax credit on foreign income.
The Finance Ministry notifies the India-Belgium protocol amending the 1993 tax treaty, effective June 26, 2025, updating definitions, information exchange, and tax collection assistance provisions.
The Bombay High Court quashed the AAR’s ruling that denied Mauritius DTAA benefits to Bid Services Division (Mauritius) Limited. The Court held that the petitioner was entitled to treaty protection on capital gains from the sale of MIAL shares. It ruled that legitimate corporate structures cannot be disregarded merely for resulting in tax advantages.
The Supreme Court’s ruling on Permanent Establishment (PE) expands taxability for MNEs, holding that “effective control and continuous direction” through operational continuity, even without a traditional fixed office, constitutes a fixed-place PE under Article 5.
Recent ITAT and High Court rulings confirm the Tax Residency Certificate (TRC) is key to claiming DTAA benefits, reinforcing protection for pre-2017 foreign investments against ‘shell company’ allegations.
Tribunal held that cost-to-cost reimbursements for IT support services do not qualify as Fees for Included Services (FIS) under Article 12 of the India-US DTAA, as no technical knowledge was “made available” to the Indian affiliate.
Understand when NRIs must file Indian income tax returns (ITR), key exemptions, and the impact of residential status (ROR, RNOR, NR) on income taxability in India. Learn about TDS rates and the tax status of NRE/NRO account interest.
ITAT Delhi ruled that a valid Tax Residency Certificate (TRC) issued by Mauritius is sufficient proof of residency to claim benefits under the India-Mauritius DTAA. The Tribunal rejected the Revenue’s attempt to deny treaty protection based on vague allegations of the assessee being a paper/shell company.
PPT provisions inapplicable in absence of separate notification incorporating MLI provisions into India-Ireland tax treaty Background The Mumbai ITAT in Sky High Appeal XLIII Leasing Company Limited v. ACIT (2025) 177 taxmann.com 579 (Mum)/ TS-1085–ITAT-2025(Mum) and the Delhi ITAT in Kosi Aviation Leasing Ltd. v. ACIT [ITA No. 994/Del/2025, dated 30-9-2025] have held that operating […]
ITAT Mumbai ruled that gains from rights entitlement transfers are exempt under Article 13(6) of the India-Ireland DTAA because they are distinct from shares, not covered by Article 13(5). The Tribunal also affirmed that short-term capital losses from STT-paid shares can be set off against short-term capital gains from non-STT-paid shares.
