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...
Direct Tax & International Tax Perspective–Part I Income Tax Returns 1. Whether there is any extension of due dates in filing the belated returns for the Financial Year 2018-19? Answer: Yes, due date income tax return for Financial Year 2018-19 was 31st March 2020. The Ministry of Finance, vide Press Release dated 24.03.2020 has extend the due […]
Explains repatriation rules for NRO accounts, including limits, permissible transfers to NRE accounts, remittance conditions, credits, debits, and FEMA compliance.
Every person who has relocated out of India, has at one point or another faced issues with respect to taxability of his income earned in India. In this article we shall be looking at the aspects that cover taxability of rental income earned from property situated in India for an individual who has been assessed […]
Finance Act, 2020 has come up with some landmark amendments in the Income Tax Act, 1961 in relation to taxation of income for Non-resident Indians making it more difficult for such people to maintain their ‘Non-resident’ tag so as to keep their foreign income out of the Indian Income Tax applicability. Indian citizens having a […]
Analysis of Definition of Capital Assets being Securities for the prospective of Non Residents including Foreign Institutional Investors as per Section 2(14) of the Income Tax Act, 1961 read with certain important circulars and letters issued by the Central Board of Direct Taxes.
With this article, we would like to explicate the concept of Foreign Companies and PE in light of Indian Income Tax Act provisions. Foreign Companies ♠ Foreign company means a company which is not a domestic company, i.e. a company registered outside India in any other foreign country. [Section 2(23A)] ♠ The Foreign Company may […]
Modification of residency provisions In order to bring prevent tax abuse the Finance Act, 2020 modified the Residency Provision. According to the un-amended Section 6, an individual is said to be resident in India in any previous year, if he— (a) is in India in that year for a period or periods amounting in all […]
Article mainly explains Amendments vide Finance Act, 2020 relating to Residential Status, Amendment Removing Dividend Distribution Tax and Impact thereof, Incorporation of MLI and Introduction of Equalization Levy on E-Com Operators.
Introduction: Determination of the residential status under Income Tax Act plays a vital role in to determine whether a person comes under the tax net or not. Section 6 of the Income Tax Act deals about the concept of resident for Income tax purposes. Finance Act 2020 dated 23.03.2020 amends Section 6 of the Income […]
Japan is in the process of shifting its goal post for Olympic Games 2020 to 2021. But its income tax details for 2019 are already out and helping millions to understand, and implement by filing tax returns at point of need. Yes, let us understand Japan Income Tax, 2019 in details for a common man. […]
