Income Tax : Income-tax Act contains special provision for taxability of a non-resident person, including a foreign company. A few benefits are...
Income Tax : Learn about Tax Deducted at Source (TDS), its purpose, applicable payments, and the rates for various categories including residen...
Income Tax : Explore key FAQs about higher TDS rates under Sections 206AA and 206AB, including applicable rates, exemptions, and compliance che...
Income Tax : Understand the TDS provisions on rent payments under Sections 194-I and 194-IB of the Income-tax Act. Know the rates, thresholds, ...
Income Tax : Learn about TDS under Section 194Q and TCS under Section 206C(1H) on goods sales and purchases, including rates, thresholds, and c...
Income Tax : Introduction: The Government of India, through the Ministry of Finance’s Department of Revenue, has provided essential updat...
Income Tax : Under the current provisions of Section 206AA, tax is required to be deducted by the deductor at a higher rate as prescribed under...
Income Tax : Rationalisation of With-Holding Tax (WHT) to Encourage Greater Subscription in Indian Debt Securities by Foreign Investors, Encour...
Income Tax : The Finance (No.2) Act of 2009 introduced section 206AA under the Income Tax Act, 1961 (the ITA) to provide that any person who is...
Income Tax : The Finance Act, 2009 introduced new provisions (section 206AA) in the Income-tax Act, 1961 (the Act). As per these provisions any...
Income Tax : Assessee was incorporated in Japan and was in the business of providing telecommunication services. Assessee provided fixed, mobil...
Income Tax : ITAT Ahmedabad upheld decision of CIT(A), ruling in favor of Nirma Limited. The nature of payments for vessel damage was deemed as...
Income Tax : ITAT Jaipur held that requirement of TDS deduction u/s. 194C of the Income Tax Act on payments made to Eco Development Committee r...
Income Tax : ITAT Bangalore held that payments received towards interconnectivity utility charges from Indian customers / end users cannot be c...
Income Tax : ITAT Bangalore held that payments received by assessee towards interconnectivity utility charges from Indian customers / end users...
Income Tax : DGIT(S)/ADG(S)-2/Compliance Check/432/2021-22 Government of India Ministry of Finance Central Board of Direct Taxes Directorate of...
Income Tax : 37BC. Relaxation from deduction of tax at higher rate under section 206AA.– (1) In the case of a non-resident, not being a compa...
Explore how Section 206AA and Section 206AB impact TDS rates. Learn when higher rates apply, exemptions for non-residents, and get answers to key questions.
Learn about Section 194-IA and essential aspects of TDS when buying property in India. Explore deductor-deductee roles, exemption criteria, deposit process, and consequences.
ITAT Bangalore held that payments received towards interconnectivity utility charges from Indian customers / end users cannot be considered as Royalty to be brought to tax in India under section 9(1)(vi) of the Income Tax Act and also as per DTAA.
ITAT Bangalore held that payments received by assessee towards interconnectivity utility charges from Indian customers / end users cannot be considered as Royalty / FTS to be brought to tax in India under section 9(1)(vi)/(vii) of the Act and also as per DTAA.
ITAT Mumbai’s ruling in Spark44 vs. ACIT case highlights failure to consider India UK DTAA provisions for tax deduction on FTS. Analysis and conclusion included.
The assessee is a company engaged in the business of Air Transport of Passengers and is a holder of Non-Scheduled Air Transport (Passenger) Services (NSOP) permit granted by the Director General of Civil Aviation / Ministry of Civil Aviation.
Karnataka High Court held that payments made to Non-resident Telecom Operators for provision of bandwidth and Inter-connectivity Usage Charge are not covered as Royalty/ FTS and, accordingly, TDS not deductible. Further, assessee is entitled to take benefit of DTAA between two countries.
ITAT Jaipur held that denial of Foreign Tax Credit merely because Form 67 was filed after the due date of filing the return under section 139(1) of the Income Tax Act is unjustified and untenable in law.
Section 206AA cannot be understood to override the charging Sections 4 and 5 of the Act. It has further held that the provision in Section 206-AA has to be read down to mean that where the deductee i.e., the overseas resident business concern conduct sits operation from a territory, whose Government has entered into a DTAA with India, the rate of taxation would be as dictated by the provisions of the treaty.
CIT International Taxation Vs Air India Ltd. (Delhi High Court) Whether ITAT has erred in holding that the rate of deduction of tax in the case of a non-resident who does not have a PAN and whose case does not lie in the exceptions laid down in Sub-Section 7 of Section 206AA of the Act […]
