Income Tax : The Income Tax Department has clarified the purpose, contents, and access to the Annual Information Statement (AIS) and Taxpayer I...
Income Tax : A detailed overview of limitation periods prescribed under the Income-tax Act reveals how missing statutory deadlines can lead to ...
Company Law : Understand Sections 89 and 90 of the Companies Act, 2013, focusing on legal ownership declarations and significant beneficial owne...
CA, CS, CMA : Discover the complexities of tax compliance for freelancers and gig workers, from understanding income sources to navigating legal...
Income Tax : Understand the concept of Updated Return under the Income-tax Act, its necessity, tax implications, and filing process. Get insigh...
Income Tax : The Central Government have notified the “Hong Kong Special Administrative Region of the People’s Republic of China” as ‘s...
Income Tax : ITAT Delhi held that IT, salary and travel reimbursements without any profit element were not taxable and deleted the disallowance...
Income Tax : ITAT held that delayed filing of Form 67 is a procedural lapse and directed the AO to grant foreign tax credit claimed under Secti...
Income Tax : ITAT held that foreign tax credit cannot be denied solely because Form No. 67 was filed after the return, subject to verification ...
Income Tax : The ITAT held that foreign exchange gains arising from realization of export proceeds from services rendered to associated enterpr...
Income Tax : The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of ...
Income Tax : The Income-tax Act, 1961 (the Act) provides that the Central Board of Direct Taxes may prescribe rules specifying the procedure fo...
Income Tax : Notification No. 3/2011 - Income Tax WHEREAS the annexed Agreement among the Governments of SAARC (South Asian Association for Re...
Income Tax : Notification No. 86/2010-Income Tax Whereas, an Agreement and the Protocol between the Government of Republic of India and the Gov...
Income Tax : Notification No. 36/2010-Income Tax Whereas, an Agreement and the Protocol between the Government of Republic of India and the Gov...
Income Tax : Notification No. 25/2010-Income Tax In exercise of the powers conferred by Explanation 2 to section 90 of the Income-tax Act, 1961...
ITAT Kolkata held that Foreign Tax Credit cannot be denied for delayed filing of Form No. 67 since the provision of DTAA override the provision of Section 90 of the Act and also filing it is directory requirement and not mandatory requirement. Accordingly, appeal allowed.
ITAT Chennai held that salary income for services rendered in China is not taxable in India. Accordingly, benefit of exemption under Article 15(1) of the DTAA between India-China. Thus, order set aside and appeal allowed.
ITAT Mumbai held that denial of claim of Foreign Tax Credit [FTC] for delayed filing of Form No. 67 not sustainable. Accordingly, order set aside and matter restored to file of AO to verify genuineness of the claim.
Delhi High Court held that payments received for services that may require technical expertise, technical inventions or technology would not qualify as Fees for Technical Services under Article 13 of the India-UK DTAA. Accordingly, appeal allowed.
ITAT Hyderabad held that denial of credit for Foreign Tax Credit merely due to delay in filing of Form 67 not justified as Form 67, although belatedly, was filed before the AO passed order u/s 143(3) of the Act. Accordingly, appeal allowed.
Understand Sections 89 and 90 of the Companies Act, 2013, focusing on legal ownership declarations and significant beneficial ownership disclosures for corporate transparency.
Delhi High Court held that the benefit of exclusion of time by virtue of Explanation (ix) of Section 153B of the Income Tax Act cannot be available here as reference made for information under Indo-Swiss DTAA was invalid. Accordingly, questions to law as framed are answered against the Revenue.
AO however, held that STCG on the sale of rights entitlement was to be taxed as “sale of shares” under Article 13(5) of the India-Ireland DTAA, making an addition towards STCG as taxable in India.
ITAT Kolkata held that filing of Form No. 67 is directory and no mandatory and the credit for foreign taxes cannot be denied for mere delay in filing the Form No. 67. Accordingly, appeal of the assessee allowed.
The Revenue alleges that the appellants/assessee got the said company CCL incorporated only for the purpose acquiring properties in UK by which he could avoid declaration of the ownership in the properties in India.
