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Countrywise Withholding Tax Rates: IT Act vs. Tax Treaties/DTAA

Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...

June 30, 2026 43609 Views 1 comment Print

Countrywise Withholding Tax Rates / Chart as per DTAA

Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...

June 30, 2026 454991 Views 28 comments Print

Understanding TDS on Immovable Property Purchases: A Buyer’s Guide

Income Tax : Section 194-IA requires buyers of immovable property to deduct TDS at 1% when the sale consideration or stamp duty value is ₹50 ...

June 7, 2026 9834 Views 0 comment Print

Section 195 TDS on Share Purchase from Non-Resident: Complete LTCG Guide

Income Tax : When a resident buys unlisted shares from a non-resident, TDS must be deducted on gross consideration under Section 195, subject t...

February 23, 2026 4095 Views 0 comment Print

TDS u/s 195 on Sponsorship & Trademark Rights – Indo-Singapore DTAA

Income Tax : Payments for sports sponsorship that grant global trademark usage can be split as royalty. Courts upheld withholding where tradema...

January 1, 2026 1197 Views 0 comment Print


Latest News


Webinar on Monthly Updates on Direct & Indirect Taxes on 3rd December 2022

Income Tax : Direct & Indirect Taxes : Monthly Updates Date & Time – 3rd December 2022 (Time:11 a.m to 12:30 p.m) Tax Guru is Organiz...

December 2, 2022 32244 Views 2 comments Print

Procedural & technical issues on IDS, 2016 clarified

Income Tax : Clarification on certain procedural and technical issues regarding the Income Disclosure Scheme, 2016 (IDS) under section 119 of t...

July 13, 2019 1491 Views 0 comment Print

Section 195: 6 Suggestions made by ICAI for Rationalization of Provisions

Income Tax : Finance Act, 2012 extended the obligation to withhold taxes to non- residents irrespective of whether the non-resident has -...

January 18, 2018 6063 Views 0 comment Print

CA Certificate not required for certain remittances: Govt

Income Tax : Government has recently modified the Foreign Exchange Management (Current Account Transactions) Rules, 2000 and the Liberalized Re...

August 10, 2015 22591 Views 6 comments Print

Vodafone ruling effect – Exporters question TDS on foreign payment post

Income Tax : The Supreme Court judgement on Vodafone tax case seems to have opened a Pandora's box with exporters too expressing reservation on...

January 25, 2012 2256 Views 0 comment Print


Latest Judiciary


Receipt of interest by foreign banks on foreign currency loans to Indian concerns was taxable on gross basis

Income Tax : Interest income earned by a foreign bank from foreign currency loans extended to Indian corporates was taxable on a gross basis. S...

July 6, 2026 108 Views 0 comment Print

Section 9(1)(vii) FTS Addition Set Aside; Taxability Must Be Examined Under Relevant DTAA: ITAT Delhi

Income Tax : ITAT Delhi held legal services are not FTS under Section 9(1)(vii) and directed partner-wise DTAA examination. FTS addition was de...

July 5, 2026 381 Views 0 comment Print

Cost-to-Cost Overseas Reimbursements Without Profit Element Not Taxable as FTS: ITAT Delhi

Income Tax : ITAT Delhi held that IT, salary and travel reimbursements without any profit element were not taxable and deleted the disallowance...

July 4, 2026 141 Views 0 comment Print

Employee Secondment Reimbursements Taxable as FTS as’Make Available’ Test Was Satisfied: Delhi HC

Income Tax : Delhi High Court held the ITAT failed to properly examine the ‘make available’ test for secondment payments, set aside its ord...

July 1, 2026 177 Views 0 comment Print

‘Make Available’ Test Not Met, No TDS on US Software Contractor Payments: ITAT Bangalore

Income Tax : ITAT held no TDS was required as the Revenue failed to prove the services made technical knowledge available under the India-US DT...

June 30, 2026 117 Views 0 comment Print


Latest Notifications


CBDT notifies Changes in TDS Return Form 26Q and 27Q

Income Tax : CBDT notifies the Income-tax (Seventh Amendment) Rules, 2025, updating Forms 26Q and 27Q to include Section 194T on payments to fi...

March 27, 2025 14190 Views 0 comment Print

Reg. Application in Form 15E for section 195(2) & 195(7) certificates

Income Tax : it has been decided that no such request for Form 15E for certificates under section 195(2) & 195(7) for a particular Financial Ye...

March 2, 2022 4590 Views 0 comment Print

CBDT notifies New Form 15E and rule 29BA

Income Tax : CBDT vide notification No. 18/2021-Income Tax, Dated: March 16, 2021 inserted new rule 29BA. Application for grant of certificate ...

March 16, 2021 33498 Views 1 comment Print

CBDT clarifies on Certificates for lower rate/nil TDS/TCS certificate

Income Tax : Clarification on orders dated 31.03.2020 and 03.04.2020 issued under section 119 of the Income-tax Act, 1961 (the Act) by CBDT vid...

April 9, 2020 12126 Views 0 comment Print

Lower/nil rate of TDS/TCS applications to be disposed liberally by 27.04.2020

Income Tax : In case of pending applications for lower/nil rate of TDS/TCS for F.Y. 2019-20, the Assessing Officers have been directed to dispo...

April 3, 2020 6036 Views 1 comment Print


TDS u/s. 195 not attracted on salary paid outside India towards staff hired outside India

March 10, 2025 1119 Views 0 comment Print

ITAT Delhi held that provisions of section 195 as well as section 40(a)(iii) are not attracted in case of salary paid to staff hired outside India and services were utilised outside India. Accordingly, appeal of the revenue dismissed.

No addition u/s 69B as seized quantity of jewellery was under the Limit prescribed by Circular No. 1916

March 10, 2025 1098 Views 0 comment Print

It was held that considering the provisions of CBDT Circular No. 1916 and the explanation provided by the assessee, the seized gold jewellery up to the specified thresholds for each family member should be treated as explained.

CBDT Circular Cannot Override Statutory Provisions by Prescribing Limitation Period Absent in Income Tax Act

March 5, 2025 1488 Views 0 comment Print

The writ petitioner impugns the order dated 27 March 2018 in terms of which the respondent has come to reject applications filed by it seeking refund of excess tax wrongly deducted and deposited u/s. 195 of the Income Tax Act, 1961.

No TDS on Payments to Non-Residents for Social Media Ads: Karnataka HC

February 22, 2025 1503 Views 0 comment Print

Karnataka High Court held that TDS is not deductible on payment to non-residents for advertisements in several social medias like Facebook, Amazon Web Services and Rocket Science Group. Accordingly, appeals are dismissed.

Section 264 Revision Accepted: Suo Moto Disallowance Rectified

February 12, 2025 1098 Views 0 comment Print

Delhi High Court held that suo moto disallowance with bona fide yet mistaken belief that amount is liable to be offered for taxation, such mistake can be rectified via revision application under section 264 of the Income Tax Act.

Reopening u/s. 148 after four years without failure to disclose material facts unsustainable

February 10, 2025 1056 Views 0 comment Print

ITAT Bangalore held that reopening of assessment under section 148 after expiry of four years without failure on part of assessee to disclose fully and truly all material facts is invalid and hence liable to be quashed.

Discounting charges not interest for TDS & cannot be disallowed under Section 40(a)(i)

February 8, 2025 3765 Views 0 comment Print

Delhi High Court upheld ITAT’s decision in CIT vs. Cargill Global Trading, ruling that discount charges are not interest and not subject to TDS under Section 195.

Transfer pricing disallowance as assessee failed to prove any benefit not justifiable: ITAT Bangalore

January 29, 2025 924 Views 0 comment Print

ITAT Bangalore held that merely because the assessee has failed to prove any benefit from services received the disallowance of transfer pricing cannot be made. Accordingly, one more opportunity granted to assessee to prove the case.

TDS not deductible on commission paid to foreign agents as no PE in India

January 27, 2025 2394 Views 0 comment Print

ITAT Chennai held that payments are in the nature of selling commission to foreign agents who is not having permanent establishment or business connection in India is not taxable in India and accordingly, TDS u/s. 195 not deductible.

No section 271-I Penalty for Non-Filing of Form 15CA/15CB on Import Payments

January 21, 2025 1449 Views 0 comment Print

Assessee was engaged in the business of manufacturing of diamond by cutting and polishing of rough diamond and sale thereof. During assessment, Assessing Officer noted that assessee has made 20 transactions of foreign remittance.

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