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...
Reimbursement of expenses qua marketing fees, frequent flyer programme, frequent guest programme and reservation fees received by assessee cannot be treated as fee for technical services: HC
Delhi High Court dismisses revenue appeal against Bharti Airtel, reaffirming that charges paid for bandwidth to overseas operators are not taxable as royalty under the Income Tax Act.
Delhi High Court rules payments for hotel centralised services like marketing and reservations are not taxable as technical fees, citing prior judgment.
Free zone businesses in the UAE face tax rules often misunderstood. Learn 11 key myths vs facts to stay compliant under UAE’s new corporate tax law.
ITAT Delhi rules commission to Amway distributors is not part of AMP expenses for transfer pricing adjustment. Deduction u/s 80G allowed.
ITAT Delhi held that services rendered under Intra Group Service Agreement do not make available technical knowledge and hence would not fall within the definition of FTS as provided under Article 13(4) of India UK DTAA and hence not taxable in India.
ITAT Delhi dismisses Revenue’s appeal against Tata Teleservices on taxability of interest paid to China Development Bank under India-China DTAA Article 11(3).
It also referred to similar findings in Matrix Partners India Investment Holdings, LLC vs DCIT and other precedents, reinforcing that exempt income did not form part of the computation of total income under Indian law.
ITAT Delhi rules Crocs Inc.’s service income not taxable in India under DTAA, as services did not “make available” technical knowledge to Crocs India.
ITAT Mumbai rules Sita USA’s airline software services not taxable in India under FTS or DTAA. Revenue appeals for AY 2014-15 to 2021-22 dismissed.
