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...
PPT provisions inapplicable in absence of separate notification incorporating MLI provisions into India-Ireland tax treaty Background The Mumbai ITAT in Sky High Appeal XLIII Leasing Company Limited v. ACIT (2025) 177 taxmann.com 579 (Mum)/ TS-1085–ITAT-2025(Mum) and the Delhi ITAT in Kosi Aviation Leasing Ltd. v. ACIT [ITA No. 994/Del/2025, dated 30-9-2025] have held that operating […]
ITAT Mumbai ruled that gains from rights entitlement transfers are exempt under Article 13(6) of the India-Ireland DTAA because they are distinct from shares, not covered by Article 13(5). The Tribunal also affirmed that short-term capital losses from STT-paid shares can be set off against short-term capital gains from non-STT-paid shares.
ITAT deleted a Rs.54.85 crore tax addition, holding that make available clause of the India’s DTAA was not satisfied because routine IT support did not enable Indian entity to apply technology without provider’s ongoing reliance. A key takeaway is that mere recurring service provision, even with technical input, does not constitute make available of know-how.
Global tax system is struggling with digital economy’s value creation. OECD’s Pillars 1 & 2 introduce new taxing rights and a 15% minimum tax to combat profit shifting.
The ITAT Delhi ruled that Marketing & Reservation Contributions (MRC) received by a US-based hotel brand entity from Indian franchisees are not taxable as Fees for Technical Services (FTS) or Royalty under the India-US DTAA. The Tribunal followed the principle of judicial consistency, reiterating that these receipts were not compensation for managerial or technical services.
Notification implements the India-Qatar Double Taxation Avoidance Agreement (DTAA) and Protocol, effective from the next fiscal year, outlining rules for income tax, business profits, dividends, and interest to prevent fiscal evasion.
ITAT Delhi held that the absence of office premises and expatriate activity meant the assessee had no Permanent Establishment (PE) in India. The Tribunal ruled that Revenue cannot rely solely on past orders without verifying current-year facts.
Detailed comparison of dividend, interest, royalty, and FTS withholding tax rates between India’s Income-tax Act and over 60 Double Taxation Avoidance Agreements (DTAAs).
Discover who must file Form 1040 or 1040-SR in 2025, key deductions, and credits. Learn filing deadlines, penalties, and electronic options for accurate tax compliance.
Summary of key income tax benefits and residency rules for non-residents (NRs) in India for AY 2026-27. Covers the scope of taxation on India-sourced income, residency tests (Section 6, 6(1A)), special presumptive tax schemes, and exemptions for Foreign Diplomats, FIIs, and IFSC units.
