Income Tax : Understand Permanent Establishment in India, its types, and the legal framework. Learn about taxation laws, DTAA provisions, and k...
Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...
Income Tax : Learn about India's Equalisation Levy, targeting digital transactions like online advertisements by foreign e-commerce firms. Unde...
Income Tax : Explore the impact of BEPS principles and MLI framework on India's Double Taxation Avoidance Agreements (DTAA). Detailed analysis ...
Income Tax : Explore complexities of Business Connection and Permanent Establishment for companies in India. Understand tax implications, signi...
Income Tax : The OECD Committee on Fiscal Affairs has proposed important and far-reaching changes to the Commentary on Article 5 (Permanent Est...
Income Tax : A host of companies from Mumbai, said to be 367 in number and mostly multinational in nature, have moved the recently set up dispu...
Income Tax : A Double Taxation Avoidance Agreement was signed between India and Tajikistan today, i.e. 20th November, 2008. The Agreement was s...
Income Tax : Bangalore ITAT overturns AO's PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and inter...
Income Tax : Delhi High Court examines Nokia Network OY’s Permanent Establishment (PE) status in India, addressing taxation on software reven...
Income Tax : Delhi HC rules Samsung India not a 'Permanent Establishment' of Samsung Korea. No tax liability under India-Korea DTAA for seconde...
Income Tax : Delhi HC rules Krones' Indian subsidiary is not a Dependent Agent PE, dismissing the tax authority's appeal....
Income Tax : Delhi High Court clarifies taxability of profits attributed to a Permanent Establishment (PE) under the India-UAE DTAA, even when ...
Income Tax : CBDT notifies Section 206C (1G) of Income Tax Act shall not apply to a person (being a buyer) who is a non-resident & who does not...
Income Tax : Public Consultation on the proposal for amendment of Rules for Profit attribution to Permanent (PE) Establishment invited by CBDT....
Delhi High Court quashes reassessment notices by DCIT after TPO settles arm’s length remuneration issue. Detailed analysis of Progress Rail Locomotive Inc. vs DCIT case.
CIT Vs Mitsubishi Corporation India P. Ltd (Delhi High Court) The Delhi High Court deliberated on an appeal concerning Assessment Year (AY) 2006-07, where the Income Tax Appellate Tribunal (ITAT) had made decisions impacting the applicability of Section 40(a)(i) of the Income Tax Act, 1961, in relation to the Double Tax Avoidance Agreements (DTAAs) between […]
Delhi High Court’s judgment in CIT vs. Fox Network Group Singapore PTE Ltd. clarifies income tax treatment of live transmission fees under Income Tax Act Section 9(1)(vi).
Delhi HC upholds 15% attribution rate of revenue for Indian operations of Permanent Establishment based on gross booking by Travelport Global Distribution Systems B.V.
Explore the impact of BEPS principles and MLI framework on India’s Double Taxation Avoidance Agreements (DTAA). Detailed analysis of the India-Singapore DTAA, changes in PE clauses, and post-BEPS amendments.
Explore Delhi High Court’s ruling in CIT vs Ricardo U.K. Limited. No profit attribution if commission paid to Ricardo India is adjusted against PE profit. Detailed analysis and implications.
Explore complexities of Business Connection and Permanent Establishment for companies in India. Understand tax implications, significance, and scenarios.
Explore the latest in international taxation: from judicial precedents to regulatory changes. Dive into cases, form updates, and MFN clause implications.
Explore the intricacies of Permanent Establishment in international taxation, from UN Model to domestic laws. Learn about key provisions, tests, and recent developments. Contact us for clarity on International Taxation/DTAA.
Double taxation can be a concern when a person residing in India earns income that is also taxable in a foreign country. To address this issue, individuals can claim credit for taxes paid outside India as Foreign Tax Credit (FTC)
