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...
The Delhi High Court ruled that subscription fees for Salesforce CRM software are not royalty income under the India-Singapore DTAA or the Income Tax Act, citing prior judicial precedents.
Understand India’s SPAC taxation complexities, from capital gains and PE issues to tax arbitrage. Explore tax-efficient alternatives like GDRs and direct foreign listings, offering streamlined paths for Indian companies navigating global capital markets.
The charges paid by the Assessee’s customers are for availing services, which the Assessee provides by using its proprietary equipment and other assets. No part of its equipment or IPRs are alienated by the Assessee in favour of its customers for their use.
Delhi ITAT rules Coursera’s online course receipts from India are not taxable as Fees for Included Services, citing prior judicial precedents.
Understand role of Form 10F for non-residents to claim Double Taxation Avoidance Agreement (DTAA) benefits and avoid higher withholding tax in India.
Bangalore ITAT rules AO exceeded jurisdiction by reclassifying online education income as FTS after a limited remand, deleting the tax demand.
SC ruling clarifies software payments aren’t royalty if no copyright is transferred. DTAA compliance, including TRC and Form 10F, remains essential.
India’s Finance Act 2025 clarifies Significant Economic Presence (SEP) rules, excluding mere purchase of goods in India for export from tax liability.
ITAT Delhi rules GoDaddy’s income from domain registration and web services is not taxable as royalty or FTS/FIS, citing judicial precedents.
Delhi High Court upholds ITAT ruling for Starwood Hotels, stating payments for centralized services not FTS, citing binding precedent despite Supreme Court appeal.
