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...
Ahmedabad ITAT’s order in Atul Limited vs DCIT case discusses TP adjustments, volume discount, geography adjustments, and more. Detailed analysis provided.
In a detailed analysis of Axis Bank Limited Vs ACIT case, Ahmedabad ITAT explains the difference between a Letter of Credit and Corporate Guarantee, resolving disallowance disputes.
Learn about the tax dispute between Diamond Manufacturing Management and the Indian Revenue Authority, involving fees for technical collaboration and the absence of Permanent Establishment.
Understanding taxation for NRIs: Learn about residential status, taxable income, deductions, and the importance of Double Taxation Avoidance Agreements (DTAA) in India.
Explore the nexus between tax avoidance and inequality in India. Learn how legal loopholes deepen economic divides and discover strategies to address this pressing issue.
Learn about tax implications of offshore indirect transfers of Indian capital assets by non-resident entities. Explore Vodafone case, amendments to Income Tax Act, and Explanation 5 of Section 9(1)(i).
Discover the intricacies of structuring cross-border mergers and acquisitions (M&A). Learn about key steps, due diligence, legal compliance, and tax considerations for successful transactions.
Learn about Transfer Pricing compliance and assessment procedures, including ALP determination, TPO reference, DRP mechanism, APAs, and penalties for non-compliance.
Discover the ITAT Delhi ruling on taxing income from providing business support services to Indian group entities. Analysis of Solvay Asia vs. DCIT case under India-Thailand DTAA.
CIT – International Taxation Vs. ESPN Star Sports Mauritius S.N.C ET Compagnie (Delhi High Court) The Delhi HC affirms the order of ITAT that ESPN Distribution does not constitute a PE in India and income earned from sports channel distribution cannot be taxed as royalty under provisions of the ITA read with India-Mauritius DTAA. Background […]
