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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 : Forms 1042, 1042-S, and 1042-T are U.S I.R.S taxation forms dealing with dealings with foreign persons, including non-resident ali...
Income Tax : The UK today (Thursday 17 March) announced it is suspending the exchange and sharing of tax information with Russia and Belarus as...
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Income Tax : For income to be taxable under FTS, there must be a direct enablement or transfer of skills or knowledge, which mere advisory or c...
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Income Tax : Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and ch...
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Income Tax : Notification No. 96/2023-Income Tax: Learn about the agreement between India and Saint Vincent for tax information exchange and as...
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ITAT Delhi held that the social security, insurance, relocation expenses which are in the nature of committed and obligated payments are in the nature of reimbursements and not fee for technical services.
Get an insight to UAE Corporate Tax (UAE CT) – A Curtain Raiser with Federal Decree Law No. 47 of 2022. Learn about CT provisions with the help of Federal Tax Authority from June 2023.
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Companies register offshore for a variety of reasons, including tax benefits and financial privacy. Whether you need a company abroad depends on your specific business needs and goals.
payment received by the owner from the charterer has to be reckoned as payment from operations of carriage of goods from one port in India to another port in India, which falls under the ambit of carrying out shipping business or shipping operators.
The LO does not constitute a fixed place through which business of assessee is carried out in India. Employees of the LO do not negotiate, finalise or discuss the mechanics of contracts including pricing with the assessee’s customers. As such the employees of LO merely act as a communication link between the assessee and the airline companies. The LO did not carry any activity, beyond that permitted by the RBI. The activities carried by the LO are thus, preparatory (auxiliary) in nature. The activities/operations of the assessee in connection with the contracts are carried from outside India.
Rohan Hattangadi Vs CIT (A) (ITAT Mumbai) From Rule 128, it is evident that the assessee has to file Form 67 on or before the due date of furnishing the return of income as per section 139(1) of the Act, which the statement specifies as mandatory and not directory as per the word ‘shall’ used […]
Toyota Kirloskar Motor (P) Ltd Vs ACIT (ITAT Bangalore) The Appellant submits the in its own case for AY 2003-04, the Honourable Bangalore Tribunal has accepted that TP adjustment has to restricted to AE transactions. Further, in Appellants own case for AY 2013-14 [ITA No.2016/Bang/2018, dated 18.08.2021], the Honourable Bangalore Tribunal has upheld the action […]
Calcutta High Court held that rendering of advisory service doesn’t amount to Fees for Technical Services/ Fees for Included Services under Article 12(4)(b) of the India-US Double Taxation Avoidance Agreement.
Michael Page International Pte Limited Vs DCIT (ITAT Mumbai) ITAT held that unless the recipient of the services, by virtue of rendition of services by the assessee, is enabled to provide the same services without recourse to the service provider, the services cannot be said to have made available the recipient of services. A mere […]
