Income Tax - In this article, author will discuss the implication of Hong Kong and India both completing their relevant procedures in respect to double tax avoidance agreement (DTAA). Further it will be analyzed in detail meaning of various dates in respect to India – Hong kong DTAA and date from which it can be used for remittance to Hong Kong Resi...
Read MoreIncome Tax - A Company is a separate legal entity from its shareholders. Under S.2 (7) of the Income Tax Act, all entities can be shareholders. For example, sometimes Companies themselves are shareholders in other companies and draw Inter Corporate Dividends from the other. ...
Read MoreIncome Tax - Every year the residential status of the taxpayer is to be determined by applying the provisions of the Income-tax Law designed in this regard (discussed later) and, hence, it may so happen that in one year the individual would be a resident and ordinarily resident and in the next year he may become ...
Read MoreIncome Tax - The Finance Act, 2012 expanded the scope of the term International Transaction thereby giving the clarity as to what the legislature meant or rather deemed fit to be International Transaction and consequential amendments were also made to other connected sections of Transfer Pricing in the Income-tax Act, 1961. ...
Read MoreIncome Tax - Germany has been changing income tax laws since 1964 to keep pace with the changing industrial scene in the world. Its complex income tax structure and progressive tax rates are explained in this article. With the opening up of their economy for working professionals from software super power like India, Indian professionals have started ...
Read MoreIncome Tax - ICAI released an e-book on Taxation of Non-Residents based on the law as amended by the Finance Act, 2018. The book contains following topics- Chapter 1. Residential Status Chapter 2. Income Deemed to Accrue or Arise in India Chapter 3. Income not to be included in the total income Chapter 4. Presumptive Taxation Chapter 5. […]...
Read MoreIncome Tax - The Protocol provides internationally accepted standards for effective exchange of information on tax matters. Further, the information received from Kazakhstan for tax purposes can be shared with other law enforcement agencies with the authorisation of the competent authority of Kazakhstan and vice versa....
Read MoreIncome Tax - The Government of India issues clarification regarding requirement for furnishing of Country-by Country Report under Section 286(4) of Income Tax Act, 1961. ...
Read MoreIncome Tax - ICRICT is launching today a new publication presenting concrete solutions to reorient the existing system of international taxation away from serving the wealthy few and to focus it instead on addressing the needs of the vast majority of the population....
Read MoreIncome Tax - Finance Act, 2012 extended the obligation to withhold taxes to non- residents irrespective of whether the non-resident has -...
Read MoreMoet Hennessy India Pvt Ltd Vs ACIT (ITAT Delhi) - Moet Hennessy India Pvt Ltd Vs ACIT (ITAT Delhi) In the present case, no new facts have emerged and all the facts brought to record, during the course of the assessment proceedings, do not indicate legally sustainable basis for coming to the conclusion that there was an internal transaction in res...
Read MoreSamsung Electronics Co. Ltd. Vs. DCIT (Int. Taxation)- ITAT Delhi - Samsung Electronics Co. Ltd. Vs. DCIT (Int. Taxation)- ITAT Delhi Analysis of the Samsung Case on the Determination of a Permanent Establishment (PE) for Services Provided by Seconded Employees of a Korean Parent to Its Subsidiary in India This article examines the ruling of the Delhi Bench of the I...
Read MoreBellsea Ltd. Vs ADIT International Taxation (ITAT Delhi) - Onus is heavily upon the revenue to establish that that assessee's activity had crossed the threshold period of 12 months and hence constitutes PE in India in terms of Article 5(2)(g) so as to tax the receipts in India as per Article 7....
Read MoreRenault India P. Ltd. vs. DCIT (ITAT Chennai) - Renault India case: Just because assessee mentioned that marketing expenditure incurred by it helped promotion of Renault brand in India, it cannot be presumed that such expenditure resulted in any international transaction ...
Read MoreShilpa Shetty Vs ACIT (ITAT Mumbai) - Shilpa Shetty case: Recording of 'satisfaction' about the existence of an international transaction was only within the jurisdiction of the AO and CIT(A) could not substitute his satisfaction for that of the AO....
Read MoreNotification No. 89/2018-Income Tax / S.O. 6247(E) - (21/12/2018) - Republic Of India And Government Of Hong Kong Special Administrative Region Of People’s Republic Of China For Avoidance Of Double Taxation And Prevention Of Fiscal Evasion With Respect To Taxes On Income ...
Read MoreInstruction No. 6/2018 - (22/11/2018) - India being a G20 Country is committed to implement the minimum standards laid down in the Base Erosion and Profit Shifting (BEPS) Project. One of the minimum standards that every participating jurisdiction has to achieve is to ensure a Transparency Framework for spontaneous exchange of rulings unde...
Read MoreNotification No. 43/2018-Income Tax [S.O. 4724 (E)] - (16/09/2018) - CBDT notifies protocol amending India-Portuguese DTAA vide Notification No. 43/2018- Income Tax Dated: 11th September, 2018...
Read MoreNotification No. 93/2017-Income Tax [S.O. 3512(E)] - (02/11/2017) - 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...
Read MoreNotification No. 92/2017-Income Tax [S.O. 3497(E)] - (31/10/2017) - Information and documents to be kept and maintained under proviso to sub-section (I) of section 92D and to be furnished in terms of sub-section (4) of section 92D. 10DA. (1) Every person, being a constituent entity of an international group shall,-...
Read MoreNotification No. 89/2018-Income Tax / S.O. 6247(E) - (21/12/2018) -
Instruction No. 6/2018 - (22/11/2018) -
Moet Hennessy India Pvt Ltd Vs ACIT (ITAT Delhi) -
Samsung Electronics Co. Ltd. Vs. DCIT (Int. Taxation)- ITAT Delhi -