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TDS Obligations: Reimbursement of Expenses vs. Fee for Technical Services

Income Tax : Delhi HC rules reimbursements to NRAEs not subject to TDS as "fees for technical services," clarifying scope of Section 9(1)(vii) ...

September 25, 2024 1170 Views 0 comment Print

An Insight Into Tax Avoidance, Backed By Recent Developments

Income Tax : Explore the legal boundaries of tax avoidance, recent rulings, and the evolving jurisprudence in India with key cases like Vodafon...

September 12, 2024 1128 Views 0 comment Print

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

Income Tax : Countrywise withholding tax rates as per the Income Tax Act compared to tax treaties/DTAA. Understand differences & implications f...

September 3, 2024 39613 Views 1 comment Print

Countrywise Withholding tax rates / Chart as per DTAA

Income Tax : Withholding tax rates for dividends, interest, royalties and Fee for Technical Services in different countries. Understand how tax...

September 3, 2024 420977 Views 28 comments Print

Sale of Property in India by an NRI – TDS provisions for Buyers & Sellers

Income Tax : Understand TDS provisions for buyers and sellers in the sale of property in India by an NRI. Get insights into tax rates, implicat...

July 24, 2024 221904 Views 57 comments 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 31830 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 1182 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 5715 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 21583 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 2076 Views 0 comment Print


Latest Judiciary


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

Income Tax : The writ petitioner impugns the order dated 27 March 2018 in terms of which the respondent has come to reject applications filed b...

March 5, 2025 171 Views 0 comment Print

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

Income Tax : Karnataka High Court held that TDS is not deductible on payment to non-residents for advertisements in several social medias like ...

February 22, 2025 201 Views 0 comment Print

Section 264 Revision Accepted: Suo Moto Disallowance Rectified

Income Tax : Delhi High Court held that suo moto disallowance with bona fide yet mistaken belief that amount is liable to be offered for taxati...

February 12, 2025 249 Views 0 comment Print

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

Income Tax : ITAT Bangalore held that reopening of assessment under section 148 after expiry of four years without failure on part of assessee ...

February 10, 2025 411 Views 0 comment Print

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

Income Tax : Delhi High Court upheld ITAT’s decision in CIT vs. Cargill Global Trading, ruling that discount charges are not interest and not...

February 8, 2025 537 Views 0 comment Print


Latest Notifications


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 3642 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 30504 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 11508 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 5664 Views 1 comment Print

Certificates for lower rate/nil deduction/collection of TDS or TCS- Reg.

Income Tax : CBDT Order on issue of certificates for lower rate/nil deduction/collection of TDS or TCS uls 195, 197 and 206C (9) when Assesee w...

March 31, 2020 57990 Views 4 comments Print


Sale of Online Advertisement Space Not Taxable as Royalty or FTS in India: ITAT Bangalore

April 2, 2024 888 Views 0 comment Print

ITAT Bangalore held that payment made by Google India Pvt. Ltd. to Google Ireland Limited (assessee) for sale of online advertisement space is not taxable in India as the same cannot be regarded as royalty or FTS.

TDS u/s. 195 not deductible on expense of management and marketing support service paid to foreign company: ITAT Delhi

March 27, 2024 1890 Views 0 comment Print

ITAT Delhi held that expense towards management and marketing support service paid to foreign company is not taxable under Fee for Technical Service (FTS) under India-Netherlands Double Taxation Avoidance Agreement (DTAA) and hence TDS not deductible u/s. 195 of the Income Tax Act.

Payment towards interconnect usage charges to foreign telecom operators not taxable in India: ITAT Mumbai

March 23, 2024 561 Views 0 comment Print

ITAT Mumbai held that the payment made towards interconnect usage charges to foreign telecom operators does not accrue or arise in India and in the absence of any permanent establishment in India could not be brought to tax in India under Article 7 of DTAA.

Physical rendition of service in India required as virtual service PE not considered under India-Singapore DTAA: ITAT Delhi

March 19, 2024 573 Views 0 comment Print

ITAT Delhi held that there is no provision regarding establishment of virtual service PE under India-Singapore DTAA and hence physical rendition of service in India is required under India-Singapore DTAA as per present service PE.

Technical service in section 9(1)(vii) denote services catering to special needs and not facility provided to all: Delhi HC

March 18, 2024 732 Views 0 comment Print

Delhi High Court held that use of facility does not amount to technical services, as technical services in section 9(1)(vii) of the Income Tax Act denote services catering to the special needs of the person using them and not a facility provided to all. Thus, order denying NIL/ lower TDS certificate quashed as services provided doesn’t amount to technical service.

TDS not deductible on payment to non-resident for availing General Business Support Service: Bombay HC

March 6, 2024 1404 Views 0 comment Print

Bombay High Court held that payments made to non-resident for availing General Business Support Service under Cost Contribution Arrangement is not in the nature of fees for ‘technical services’ and accordingly tax is not deductible on the same.

Payments for marketing services not taxable as FTS: ITAT Bangalore

March 4, 2024 1581 Views 0 comment Print

Delve into the detailed analysis of DCIT Vs AD2PRO Media Solutions Pvt. Ltd. case where marketing services rendered by a US entity in India were deemed not taxable, offering insights into tax benefits.

Legal Database Subscription not Copyright Transfer, Fee Not Royalty: Delhi HC

February 28, 2024 903 Views 0 comment Print

Delhi High Court judgment in CIT vs. RELX Inc clarifies legal database subscriptions aren’t copyright transfers or royalty. Insights on taxation implications.

Income from Indian Entities to Volvo Information Technology AB Not Taxable as Royalty: Delhi HC

February 24, 2024 492 Views 0 comment Print

Delhi ITAT rules in favor of Volvo Information Technology AB, declaring receipts from Indian entities not taxable as royalty, aligning with SC precedents.

HC allows refund of Excess TDS deducted under section 195 to deductor 

February 16, 2024 2901 Views 0 comment Print

Explore the judgment of Delhi High Court in Tupperware India Pvt. Ltd. Vs CIT regarding the refund of excess TDS under Section 195 of the Income Tax Act, 1961.

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