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...
ITAT Delhi held that the Force of Attraction Rule doesn’t apply unless there is even a remote link between the activities of other projects is established with the PE.
Notification No. 24/2023- Income-Tax Dated: 03rd May, 2023 under section 90(1) of Income tax Act, 1961 regarding Agreement and Protocol between the Government of the Republic of India and the Government of the Republic of Chile for the Elimination of Double Taxation and the Prevention of Fiscal Evasion and Avoidance with respect to taxes on […]
Form 10F is required to be file by a non-resident taxpayer with income tax department India as per section 90(5) and section 90A (5) of income tax act 1961, to claim the relief under applicable double taxation avoidance agreement.
Foreign Tax Credit allowable as assessee filed return of income & statement in Form-67 within due dates as extended by Finance Ministry
Explore the intricate taxation system of Mexico and its impact on Indias trade relations. Learn about resident and non-resident tax rates, corporate tax, VAT, and recent reforms. Stay informed for successful cross-border trade.
Income Tax Act has contained various provisions relevant to Non-Resident person depend upon its residential status, Scope of Income, business connection or permanent establishment in India etc.
Understand the complexities of income deemed to accrue arise in India for non-residents. Learn about taxability on business connections, property, salary, interest, dividends, royalties, and fees for technical services. Stay informed to navigate taxation rules effectively.
Subscription revenue received by assessee in Chemical Extract Service and Publication division does not qualify as ‘Royalty’ in terms of section 9(1)(vi) of the Act & Article–12(3) of India–USA DTAA.
Explore the determination of taxability for Non-Resident Individuals (NRIs) in India. Understand the steps involving residential status identification, tax incidence, and the choice between existing and new tax regimes. Learn about TDS, tax liability calculation, and the impact of Double Taxation Avoidance Agreements (DTAA) on NRIs. Get insights into the technical aspects of income taxation for NRIs under the Income Tax Act 1961.
Filing of Form No. 67 under Rules 128 of Income Tax Rules is a procedural requirement, therefore, is a directory in nature, non-compliance thereof does not disentitled assessee in claiming Foreign Tax Credit (FTC)
