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...
Chapter XVIIB of the Act relates to deduction of tax at source. The provisions of this chapter provide for TDS on various payments at rates contained therein. It is proposed to provide for TDS by person responsible for paying any sum to any resident for purchase of goods. The rate of TDS is kept very […]
DCIT Vs. Edgeverse Systems Ltd. (ITAT Bangalore) The question before the special bench was whether the provisions of section 206AA had overriding effect for all other provisions of the Act, whether the assesse has to deduct tax at source at the rates prescribed in section 206AA in case the payees are unable to furnish their […]
The issue under consideration is whether the architectural services provided to Singapore Entity taxable at 10% or 20% when the benefit of Double Taxation Avoidance Agreement (DTAA) is available?
DCIT Vs Bharath Fritz Werner Ltd. (ITAT Bangalore) At the time of hearing it was not disputed that the issue raised by the revenue in its appeals are already decided by a Special Bench of ITAT, Hyderabad. The issue regarding the applicability of provisions of section 206AA of the Act, in cases of tax to […]
whether the assessee has to deduct tax at source at the rates prescribed in section 206AA in case the payees are unable to furnish their PANs, even if tax liability arises out of the treaty?
Whether provisions of Section 206AA overrides DTAA? -When it comes to deduction of TDS while remitting any payment to Non Resident the beneficial provisions of DTAA & Income Tax Act -Provisions in the DTAA clearly ovveride the provisions of the Act, to the extent the provisions are more favourable to the -As per section 206AA, […]
In order to reduce compliance burden, it is proposed to amend the said section 206AA so as to provide that the provisions of this section shall also not apply to a non-resident, not being a company, or to a foreign company, in respect of any other payment, other than interest on bonds, subject to such conditions as may be prescribed.
This article discuss Provisions and Scope of Section 194-IA, Payments covered, Who is Payer/Payee, Conditions to be satisfied for applicability of section 194-IA, Time of deduction of tax, Rates of TDS, Effect of non-furnishing of PAN on rate of tax, Certificate/statement for tax deducted at source, Furnishing of statements by tax deductor to department, Some […]
Section 206AA does not override provisions of section 90(2) and in case of payment made to non-resident, assessee correctly applied rate of tax prescribed under concerned DTAAs and not as per section 206AA because provisions of the DTAAs were more beneficial and DTAA acquired primacy in such case.
Introduction Any sum payable to a non-resident including a foreign company is liable to withholding of tax under section 195 of the Income Tax Act, 1961. The tax rate may vary in accordance with the nature of the remittance which should fall within the scope of Section 9. Further, in accordance with the penal provisions […]
