Income Tax : The Double Tax Avoidance Agreement (DTAA) is essentially a bilateral agreement entered into between two countries. The basic objec...
Income Tax : Tax Residency Certificate (TRC) For Indian Resident Assessee From 01.4.2013 the India Residents who earns Income from Countries ...
Income Tax : Mumbai Income Tax Appellate Tribunal (Tribunal) [2010-TIOL-195-ITAT-MUM] in the case of Valentine Maritime Mauritius Ltd (Taxpayer...
Income Tax : Mumbai bench of the Income-tax Appellate Tribunal (the Tribunal) in the case of JCIT v. State Bank of Mauritius Ltd. (2009-TIOL-71...
Income Tax : Tribunals upheld the concept of ‘make available’ and held specified services not Fees for technical services Mumbai and Bangal...
Income Tax : Government is contemplating to revise the tax treaties with partner countries to enable the Central Bureau of Investigation (CBI) ...
Income Tax : Since 1st April, 2014 till date, the Central Board of Direct Taxes has resolved 180 cases under MAP. The total amount of income lo...
Income Tax : The Union Revenue Secretary, Mr Sunil Mitra, said here on Tuesday that domestic tax policy would gradually move towards treaty ove...
Income Tax : Seeking the help of a friendly official or agent of a foreign bank to open a bank account overseas may not be a good idea as tax s...
Income Tax : The government has concluded the renegotiation for widening the ambit of its tax treaty with Switzerland to access information on ...
Income Tax : Delhi High Court held In the case of DIT vs. New Skies Satellite BV that the Vienna Convention on the Law of Treaties, 1969 (VCLT)...
Income Tax : Delhi High Court in the case of DCIT v. Cargill Global Trading (I) (P) Limited on the issue of whether discounting charges paid to...
Income Tax : Recently, the Chennai bench of the Income-tax Appellate Tribunal in the case of Wheels India Ltd. v. ACIT I.T.A No. 1793/Mds/2006...
Income Tax : Limitation on deduction of expenses under Section 44D of the Act cannot be invoked if the consideration received by the foreign co...
Income Tax : Recently, the Mumbai bench of the Income-tax Appellate Tribunal (the Tribunal) in the held that mere provision of a dredger on dry...
It is indeed heartening to note that the tax rates applicable to non-resident corporates are sought to be brought at par with the domestic companies, to be taxed at the rate of 25 per cent. However, correspondingly, the concept of the branch profit tax is proposed to be introduced (which appears to be somewhat akin […]
In India, the law is settled that tax avoidance is legal and evasion is not. A taxpayer may create a device to arrange his commercial affairs to minimise his tax liability and its acceptance is based on operation of law. While revenue authorities are entitled to decipher the true meaning of a transaction, they cannot […]
Self reporting of Tax Bases & Acknowledgment [Section 148 & 154] 1. Similar to the concept of filing return of income, taxpayers have been required to file ‘Return of Tax Bases’ (‘RTB’) 2. The RTBs have to be filed on or before: • 30th June – If the person is not a company and does […]
Government has no plans to bring a new amnesty scheme for tax evaders and wants to amend the Indo-Mauritius tax treaty to curb its abuse by companies, the Rajya Sabha was informed on Tuesday. VDS schemes in the past offered amnesty to people declaring black money and paying tax. But VDS schemes cannot be hugely successful […]
In a recent ruling in case of Canoro Resources Limited1 (the taxpayer) the Authority for Advance Ruling (AAR) has held that The transfer pricing provisions shall override the general provisions provided for computing capital gains in the Income-tax Act, 1961 (the Act) in case of transfer of a capital asset by a partner to a firm by way of capital contribution in the firm.
Lucent Technologies International Inc. 1(“the assessee”) is a company incorporated in the USA. It is a tax resident of USA. It is a leading supplier of hardware and software used for GSM cellular radio telephone system. The assessee had supplied telecommunications hardware and software to its customers in India through its subsidiary Lucent Technologies India Limited (“LTIL”) (formerly known as AT&T India Private Limited).
The Income Tax Department has slapped a bill of Rs50 crore on leading private telecom company Bharti Airtel for “non-payment of taxes on interest paid on loans taken by it” and allegedly furnishing wrong information to the tax department. Bharti has contested the claim, but has also paid more than Rs40 crore to the department, […]
The government may introduce provisions in the new direct tax code to prevent misuse of double taxation avoidance agreements India has with other countries. The new code is likely to be unveiled before the year ends. A government official said a discussion paper on the code, a major initiative undertaken under the guidance of the former finance minister and present home minister P Chidambaram, is being fine-tuned.
Since August last year, the world has been watching. It all began with a show cause notice issued to Vodafone BV (based in the Netherlands), holding it to be an “assessee in default” for not withholding tax at source when it made payments to a Hutchison Group company (based in Cayman Islands) for acquiring shares of another Cayman Island company.
Income tax relief could be in store for US-bound students with New Delhi planning to seek changes in the Double Taxation Avoidance Agreement. Indian students have to pay an income tax on earnings from part-time jobs. This is because the India-US tax treaty provides for treatment of Indian students on a par with US nationals without giving a special tax relief.
