Income Tax : xplains how the functions performed by an Indian subsidiary are tested under Article 5 to determine whether a foreign company form...
Income Tax : The analysis explains how activities of a liaison office can trigger PE exposure despite regulatory approval. Taxability depends o...
Income Tax : Highlights how the Court ruled that consistent operational control and strategic oversight in India can establish a Fixed Place PE...
Income Tax : Supreme Court rules that foreign taxpayers without current projects or PE in India can still set off expenses and depreciation aga...
Goods and Services Tax : A practical guide on how India taxes imported digital services, explaining GST under RCM and when TDS applies. Key takeaway: Buyer...
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 : The Supreme Court declined to condone delay, thereby upholding the High Court’s conclusion that the liaison office did not const...
Income Tax : The judgment confirms that income from offshore equipment supply is not taxable where transactions occur outside India. The liaiso...
Income Tax : The Court set aside Section 148 notices after finding no tangible evidence supporting the existence of a Permanent Establishment. ...
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 Supreme Court declined to interfere where courts below found no permanent establishment in India due to offshore execution of ...
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....
For income to be taxable under FTS, there must be a direct enablement or transfer of skills or knowledge, which mere advisory or consultancy services might not fulfill unless such services are directly connected with a PE.
Learn about India’s Equalisation Levy, targeting digital transactions like online advertisements by foreign e-commerce firms. Understand applicability, compliance, and consequences.
Read the full text of the Delhi ITAT order on Denso (Thailand) vs ACIT, discussing tax liability for technical services under India-Thailand DTAA, absence of FTS clause, and PE considerations.
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.
