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...
Delhi High Court’s judgment in CIT vs. Fox Network Group Singapore PTE Ltd. clarifies income tax treatment of live transmission fees under Income Tax Act Section 9(1)(vi).
Explore the Thin Cap Adjustment Provisions under Section 94B of the Income Tax Act, addressing base erosion and profit shifting. Learn about its impact on NBFCs, start-ups, and global approaches.
This article sheds light on the concept of Significant Economic Presence (SEP) under Section 9 of the Indian Income Tax Act, 1961, and its implications for non-residents.
Delhi High Court upholds ITAT’s decision to exclude comparables Accentia, Eclerx, Mold-Tek, and TSR in the PCIT vs. Honeywell International transfer pricing case.
Explore the impact of Double Taxation on international business, the role of Double Taxation Avoidance Agreements (DTAA), benefits, and case laws. Learn how to apply DTAA for tax relief
Delhi High Court upholds ITAT order: Payments received for software sale/supply not considered royalty under India-Singapore Double Taxation Avoidance Agreement (DTAA).
Explore the Madras High Court’s ruling on Section 248’s inapplicability to dividend declarations. Detailed analysis and implications of the judgment.
Delhi High Court disposes of CIT Vs Zaheer Mauritius appeals, addressing taxability and capital gains nature of Compulsorily Convertible Debentures under India-Mauritius DTAA.
Explore the impact of BEPS principles and MLI framework on India’s Double Taxation Avoidance Agreements (DTAA). Detailed analysis of the India-Singapore DTAA, changes in PE clauses, and post-BEPS amendments.
Explore the dynamic landscape of international taxation, delving into emerging areas like digital companies, cross-border transactions with cryptocurrencies, and the evolving tax landscape for multinational corporations. Stay informed on transfer pricing regulations and ensure compliance for a seamless global business experience.
