Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...
Income Tax : The article explains how IRS audits are initiated and conducted to verify tax return accuracy. It highlights taxpayer duties, righ...
Income Tax : The Court held that indirect share transfers deriving value from Indian assets are taxable. Treaty benefits were denied due to tax...
Income Tax : The content outlines key filing deadlines and highlights penalties for non-compliance. The takeaway is that timely filing and paym...
Income Tax : Overview of US tax credits including refundable, nonrefundable, and partially refundable credits, with examples, forms used, and c...
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 Tribunal ruled that a Dependent Agent PE arises only if agents habitually conclude contracts or secure orders on behalf of the...
Income Tax : The Karnataka High Court ruled that interconnect service charges paid to non-resident telecom operators do not constitute royalty....
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 : 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...
Let’s talk about the tax benefits you can enjoy as an NRI in India and on Income earned outside India. Many NRIs don’t realize that the Indian tax system is pretty favorable, especially for those who mostly earn outside India.
Delhi High Court clarifies taxability of profits attributed to a Permanent Establishment (PE) under the India-UAE DTAA, even when global losses are incurred.
Assessing foreign tax credit claim rejected due to Form 67 filing delay. The CIT(A) upheld disallowance for AY 2020-21. Tribunal reviews COVID-19 extensions.
ITAT Bangalore ruled on Deepak Shimoga Padmaraju foreign tax credit claim, denied due to late filing of Form 67 after the due date for the AY 2021-22.
ITAT Delhi rules that filing Form 67 is not mandatory for Foreign Tax Credit (FTC) claims, and procedural violations shouldn’t deny the right to FTC.
ITAT Chandigarh rules that the assessee cannot be denied Foreign Tax Credit (FTC) due to delay in filing Form No. 67.
In this article, we will analyse position of composite contract that is being taken into account regarding taxability of offshore services in India.
Explore the legal boundaries of tax avoidance, recent rulings, and the evolving jurisprudence in India with key cases like Vodafone shaping fiscal policies.
ITAT Delhi rules Coursera’s income from Indian customers not taxable as Fees for Technical Services (FTS) under India-USA DTAA. A key decision for online platforms.
India and Mauritius have amended the DTAA, adding a principal purpose test (PPT) rule to close tax loopholes and align with global norms. Explore its impact on FPI and FDI.
