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Benefit to Non-Residents under Income Tax Act, 1961

Income Tax : This guide explains the tax exemptions, concessional tax rates, presumptive taxation schemes, and compliance benefits available to...

July 3, 2026 114621 Views 0 comment Print

​International Business- Income Tax Sections to be remembered

Income Tax : The guide compiles the principal Income-tax Act provisions applicable to non-residents establishing business in India and resident...

June 30, 2026 18920 Views 1 comment Print

Countrywise Withholding Tax Rates: IT Act vs. Tax Treaties/DTAA

Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...

June 30, 2026 43603 Views 1 comment Print

Countrywise Withholding Tax Rates / Chart as per DTAA

Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...

June 30, 2026 454973 Views 28 comments Print

Why Your Indian Subsidiary Abroad Might Be Triggering Tax Residency You Never Signed Up For?

Income Tax : The article explains how India's Place of Effective Management (POEM) rules may treat a foreign company as an Indian tax resident ...

June 25, 2026 432 Views 0 comment Print


Latest News


CBDT Clarifies Guidance on Principal Purpose Test (PPT)

Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...

March 17, 2025 2793 Views 0 comment Print

CRS & FATCA: Tax Transparency & Disclosure of Foreign Assets & Income

Corporate Law : Learn about CRS and FATCA, how India receives foreign account info, and the disclosure requirements for foreign assets and income ...

January 3, 2025 2094 Views 0 comment Print

Budget 2024: New Rules for Including Foreign Taxes in Total Income

Income Tax : From April 2025, foreign taxes withheld must be included in total income for accurate reporting under section 198. Aims to prevent...

July 24, 2024 1587 Views 0 comment Print

Representation to Simplify & Automate TRC Issue Process for Indian Companies

Income Tax : Explore challenges in TRC applications under DTAA by Indian companies. KSCAA proposes reforms for a simpler, efficient process. Le...

June 22, 2024 906 Views 0 comment Print

Format of Declaration of no PE in India and Form No. 10F

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 ...

May 8, 2023 121872 Views 0 comment Print


Latest Judiciary


ITAT Deletes AMP TP Adjustment as No International Transaction Existed

Income Tax : The Tribunal held that AMP expenditure incurred in India without any agreement or arrangement with the foreign AE cannot be treate...

June 28, 2026 129 Views 0 comment Print

Excess Royalty Refunded Under APA Cannot Be Taxed as Only Retained Amount Is Taxable: Bombay HC

Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...

June 20, 2026 114 Views 0 comment Print

ITAT Partly Allows TP Appeal, Revises Comparable Selection for ALP Determination

Income Tax : The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of ...

June 17, 2026 246 Views 0 comment Print

No DAPE Where Distributors Act on Principal-to-Principal Basis ITAT Delhi

Income Tax : The Tribunal ruled that a Dependent Agent PE arises only if agents habitually conclude contracts or secure orders on behalf of the...

March 12, 2026 438 Views 0 comment Print

Interconnect Service Charges Not Royalty: Karnataka HC Dismisses Appeal

Income Tax : The Karnataka High Court ruled that interconnect service charges paid to non-resident telecom operators do not constitute royalty....

December 10, 2025 549 Views 0 comment Print


Latest Notifications


India Enforces Amended DTAA with Belgium from June 2025 to Curb Tax Evasion

Income Tax : The Finance Ministry notifies the India-Belgium protocol amending the 1993 tax treaty, effective June 26, 2025, updating definitio...

November 10, 2025 1269 Views 0 comment Print

India–Qatar DTAA & Protocol Notified by CBDT

Income Tax : Notification implements the India-Qatar Double Taxation Avoidance Agreement (DTAA) and Protocol, effective from the next fiscal ye...

October 24, 2025 1797 Views 0 comment Print

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 4560 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 1464 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 933 Views 0 comment Print


Bandwidth Charges Not Royalty Under Income Tax Act: Delhi HC

May 9, 2025 1116 Views 0 comment Print

Delhi High Court dismisses revenue appeal against Bharti Airtel, reaffirming that charges paid for bandwidth to overseas operators are not taxable as royalty under the Income Tax Act.

Hotel Services Fee Not Taxable as Technical Fees: Delhi HC

May 9, 2025 1002 Views 0 comment Print

Delhi High Court rules payments for hotel centralised services like marketing and reservations are not taxable as technical fees, citing prior judgment.

UAE Corporate Tax: 11 Myths vs Facts for Free Zone Business

May 1, 2025 1353 Views 0 comment Print

Free zone businesses in the UAE face tax rules often misunderstood. Learn 11 key myths vs facts to stay compliant under UAE’s new corporate tax law.

Commission to Amway Distributors Not AMP Expense for Transfer Pricing: ITAT Delhi

May 1, 2025 1170 Views 0 comment Print

ITAT Delhi rules commission to Amway distributors is not part of AMP expenses for transfer pricing adjustment. Deduction u/s 80G allowed.

Intra-Group Services Not Taxable in India as They Fall Outside FTS Scope: ITAT Delhi

April 29, 2025 951 Views 0 comment Print

ITAT Delhi held that services rendered under Intra Group Service Agreement do not make available technical knowledge and hence would not fall within the definition of FTS as provided under Article 13(4) of India UK DTAA and hence not taxable in India.

Interest Payments to CDB Exempt under Article 11(3) of India-China DTAA

April 29, 2025 516 Views 0 comment Print

ITAT Delhi dismisses Revenue’s appeal against Tata Teleservices on taxability of interest paid to China Development Bank under India-China DTAA Article 11(3).

Exempt LTCG Under India-Mauritius DTAA Not Adjustable Against Taxable Losses: ITAT Mumbai

April 22, 2025 885 Views 0 comment Print

It also referred to similar findings in Matrix Partners India Investment Holdings, LLC vs DCIT and other precedents, reinforcing that exempt income did not form part of the computation of total income under Indian law.

Planning, HR, Legal & IT Support Not Taxable as FTS Under India-USA DTAA, Citing ‘Make Available’ Test

April 20, 2025 1365 Views 0 comment Print

ITAT Delhi rules Crocs Inc.’s service income not taxable in India under DTAA, as services did not “make available” technical knowledge to Crocs India.

Receipts from Passenger System Solutions not taxable as FTS in India: ITAT Mumbai

April 15, 2025 780 Views 0 comment Print

ITAT Mumbai rules Sita USA’s airline software services not taxable in India under FTS or DTAA. Revenue appeals for AY 2014-15 to 2021-22 dismissed.

Capital Gains on Mutual Funds by Singapore Resident Not Taxable in India: ITAT Mumbai

April 15, 2025 3735 Views 0 comment Print

ITAT Mumbai rules on Anushka Shah vs ITO case, addressing capital gains taxability on mutual fund units under the India-Singapore DTAA.

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