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 ruled DTAA exemption cannot be denied solely for non-availability of a Tax Residency Certificate (TRC). Circumstantial evidence can suffice, and DTAA prevails over domestic law.
Understand tax implications for Indian residents with income from countries without DTAA, including capital gains, rental income, and foreign tax relief.
President Trump’s “Tax Reform 2025” bill introduces extensive changes to US individual and business tax laws, affecting deductions, credits, and exemptions.
Explore why foreign exchange gains/losses, particularly on revenue items, should be excluded from Profit Level Indicator (PLI) calculations in Transfer Pricing, challenging current judicial precedence and OECD guidelines.
AO treated this amount as fees for technical services (FTS) taxable in India, and Dispute Resolution Panel (DRP) upheld the assessment. DRP looked into whether the payment made by an Indian company, FSTI, to Ethiopian Airlines (EA) was taxable in India as FTS.
ITAT Delhi remands Orange Business Services India’s transfer pricing case, ordering separate benchmarking for IT and ITES segments based on consistency and directing the use of the headcount method for expense allocation.
ITAT Ahmedabad clarifies corporate guarantees as international transactions, yet upholds Adani Ports’ appeal on no arm’s length adjustment, citing no AE benefit.
In today’s interconnected world, global trade and cross-border investments are the backbone of economic growth. No nation remains entirely self-reliant—countries rely on imports, exports, and foreign capital to drive their economies. However, this interdependence has led to complex tax issues, particularly double taxation, where the same income is taxed in more than one country. To […]
Delhi High Court upholds ITAT ruling: Cloud service subscription payments to foreign firms are not taxable as royalty under DTAA or Income Tax Act.
Delhi High Court dismisses appeals, reiterating Supreme Court ruling that payments for software use/resale are not royalties under Indian tax law. No TDS liability.
