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Tax Treaty

Latest Articles


Double Tax Avoidance Agreements & Taxation

Income Tax : The Double Tax Avoidance Agreement (DTAA) is essentially a bilateral agreement entered into between two countries. The basic objec...

September 9, 2020 198479 Views 11 comments Print

Tax Residency Certificate (TRC) for Indian & Non Resident

Income Tax : Tax Residency Certificate (TRC)  For Indian Resident Assessee From 01.4.2013 the India Residents who earns Income from Countries ...

August 23, 2018 297997 Views 27 comments Print

Mumbai Tribunal rules on computation of ‘duration test’ for determining existence of ‘Construction PE’

Income Tax : Mumbai Income Tax Appellate Tribunal (Tribunal) [2010-TIOL-195-ITAT-MUM] in the case of Valentine Maritime Mauritius Ltd (Taxpayer...

April 24, 2010 888 Views 0 comment Print

Foreign company having Permanent Establishment in India cannot be taxed at the rate applicable to domestic company

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...

January 4, 2010 3463 Views 0 comment Print

Tribunals upheld the concept of ‘make available’ and held specified services not Fees for technical services

Income Tax : Tribunals upheld the concept of ‘make available’ and held specified services not Fees for technical services Mumbai and Bangal...

December 19, 2009 4690 Views 0 comment Print


Latest News


Revise tax treaties to enable CBI and ED to use data for prosecution

Income Tax : Government is contemplating to revise the tax treaties with partner countries to enable the Central Bureau of Investigation (CBI) ...

February 3, 2017 690 Views 0 comment Print

CBDT resolves disputes to the tune of Rs 5000 crore

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...

February 16, 2016 774 Views 0 comment Print

Income tax policy would gradually move towards treaty override

Income Tax : The Union Revenue Secretary, Mr Sunil Mitra, said here on Tuesday that domestic tax policy would gradually move towards treaty ove...

December 17, 2010 345 Views 0 comment Print

Open Account outside India through Agent may invite trouble

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...

November 26, 2010 417 Views 0 comment Print

India, Switzerland agreed to widening the ambit of tax treaty

Income Tax : The government has concluded the renegotiation for widening the ambit of its tax treaty with Switzerland to access information on ...

July 31, 2010 714 Views 0 comment Print


Latest Judiciary


Unilateral amendment in DTAA is prohibited: Delhi HC

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)...

February 17, 2016 2127 Views 0 comment Print

Discounting charges on bills of exchange are not interest

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...

June 3, 2011 5462 Views 0 comment Print

Payment to US companies for ‘developing tooling’ and ‘validating new process for manufacture’ of wheels is taxable as fees for included services

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...

April 19, 2011 790 Views 0 comment Print

Applicability of Limitation on deduction of expenses u/s. 44D on consideration other then Fees for Technical Services

Income Tax : Limitation on deduction of expenses under Section 44D of the Act cannot be invoked if the consideration received by the foreign co...

January 30, 2011 1081 Views 0 comment Print

Mere provision of a dredger on dry lease for carrying out dredging activity in India does not result in the taxpayer having a PE as per the India-Neth

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...

December 2, 2010 813 Views 0 comment Print


IT professional can’t avoid tax on foreign earnings

October 10, 2007 1733 Views 0 comment Print

In a ruling which could affect tax payments of thousands of employees of Indian IT companies earning mega bucks on overseas assignments, the Authority of Advance Rulings (AAR) has said that that there was no escape from paying tax on the amount earned during a stint with the employer’s foreign affiliates.

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