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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 : Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Det...
Income Tax : Explore the ITAT Hyderabad's decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed a...
Income Tax : Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under Indi...
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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...
Income Tax : Notification No. 24/2023- Income-Tax Dated: 03rd May, 2023 under section 90(1) of Income tax Act, 1961 regarding Agreement and Pro...
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ITAT held that payment of Fees for training to Employees on soft skill & general topics cannot be treated as Fees for Technical Services (FTS)
Rule 128(9) of the Rules does not provide for disallowance of Foreign Tax Credit (FTC) in case of delay in filing Form 67
Assessing Officer is directed to tax interest on income tax refund under Article 11(2) of India- Malaysia DTAA and not as Business Income
Clearing the understanding of term contracting states mentioned under DTAA between two countries with an interesting example. Learn what a contracting state is, and how it helps to avoid double taxation in two countries.
ITAT has erred in holding that the entire payments received by the Assessee from its Indian Customers on account of Centralized Services viz. sales and marketing, loyalty programs, reservation service, technological service, operational services and training programs/human resources do not constitute ‘Fee for Technical Services’ as defined under Section 9(l)(vii) of the Income Tax Act, 1961 (the ‘Act’) or ‘Fee for included services’ as defined under Articles 12(4) (a) of the Indo-US DTAA.
The determination of residency is first step in the whole process of finalizing tax aspect of certain transaction. One need to ascertain that if any income is accrue/arise or deemed to accrue/arise in India in terms of Section 4,5 and 9 of Income tax Act.
Non-resident Indians (NRIs) are taxed in India on their income that is earned or accrued in India. NRIs are also taxed on certain capital gains, such as the sale of property in India. NRIs are not taxed on income earned outside of India, unless it is deemed to be accrued or deemed to have arisen in India.
Gain insights into Indias Mutual Agreement Procedure (MAP) and the Double Taxation Avoidance Agreement (DTAA) with Analysis of MAP Under FT & TR. Understand cross-border tax resolution and related tax disputes between countries in this guide.
ITAT held that payment received in India for providing logistics support services cannot be treated as royalty under Section 9(1)(vi) or fees for technical services under section 9(1)(vii) of Income Tax Act, 1961
Definition the Profits derived from the operation of ships or aircraft in international traffic, in the India- Singapore DTAA is exhaustive enough not only to include the air passengers but also mail, livestock or There is nothing mentioned in the India-Singapore DTAA to make an inference that the profits from transport of air passengers should not be covered under Article 8 of the Indo-Bhutan DTAA.
