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Lower & Nil Withholding Under Income Tax Act 2025: Section 395 Certificate & Section 393(6) Declaration

Income Tax : The Income-tax Act, 2025 replaces old TDS/TCS provisions with Section 395 and Form 128 while retaining the existing mechanism for ...

July 2, 2026 2313 Views 0 comment Print

Countrywise Withholding Tax Rates: IT Act vs. Tax Treaties/DTAA

Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...

June 30, 2026 43609 Views 1 comment Print

Countrywise Withholding Tax Rates / Chart as per DTAA

Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...

June 30, 2026 455015 Views 28 comments Print

Section 197 Certificates Can’t Be Denied on Overturned Past Assessments: Delhi HC

Income Tax : The court held that tax authorities cannot rely on earlier findings already set aside by appellate bodies. Each Section 197 applic...

January 28, 2026 720 Views 0 comment Print

TDS u/s 195 on Sponsorship & Trademark Rights – Indo-Singapore DTAA

Income Tax : Payments for sports sponsorship that grant global trademark usage can be split as royalty. Courts upheld withholding where tradema...

January 1, 2026 1197 Views 0 comment Print


Latest News


Additional Income-tax on distributed income by company for buy-back of unlisted shares

Income Tax : 20% Withholding Tax Rate on profits distributed by unlisted companies to shareholders through buy-back of shares Existing provisio...

February 28, 2013 1776 Views 0 comment Print

Vodafone pays over USD 400 mn more to buy Essar's 33 per cent stake

Income Tax : Ending year-long battle, UK-based Vodafone has agreed to pay USD 400 million more to its Indian partner Essar for buying its 33 pe...

July 3, 2011 979 Views 0 comment Print

After Vodafone verdict IT department will investigate more cross-border mergers involving Indian assets

Income Tax : The government will look into more cross-border mergers involving Indian assets, like the Vodafone-Hutchison deal, after the Bomba...

September 11, 2010 1187 Views 0 comment Print

Reminder : Person receiving income subject to withholding tax is required to obtain Permanent Account Number (PAN)

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...

July 4, 2010 1391 Views 0 comment Print

Replacement of dividend distribution tax with withholding tax to boost business

Income Tax : The cost of doing business in India could come down if the dividend distribution tax (DDT) levied on foreign shareholders is repla...

June 30, 2010 3065 Views 0 comment Print


Latest Judiciary


No FTS on Project-Specific Design Services; ‘Make Available’ Test Not Met, No Disallowance u/s 40(a)(i)

Income Tax : The Tribunal held that consultancy payments for architectural services were not FTS since no technical knowledge was made availabl...

April 16, 2026 369 Views 0 comment Print

No TDS on Foreign Commission as Income Not Taxable in India: ITAT Rajkot

Income Tax : The Tribunal rejected the Revenue’s argument that taxpayers must seek AO determination under Section 195(2) in all cases. It hel...

April 10, 2026 654 Views 0 comment Print

Virtual Service PE Not Valid Ground to Deny Nil Withholding Certificate: Delhi HC

Income Tax : The court examined whether withholding tax could be imposed solely on the basis of an alleged virtual service permanent establishm...

January 19, 2026 582 Views 0 comment Print

DDT Must Follow DTAA Limits Because Dividend Is Shareholder Income: Bombay HC

Income Tax : Court held that dividend remains income of the shareholder and DDT is an additional income tax covered under Article 2, restrictin...

December 11, 2025 1443 Views 0 comment Print

SC Admits Tesco Plea on Service Tax for Overseas Employee Secondment

Income Tax : Supreme Court admits appeal by Tesco Bengaluru against CESTAT ruling on reverse charge service tax for seconded overseas employees...

October 17, 2025 525 Views 0 comment Print


Latest Notifications


CBDT notifies New Form 15E and rule 29BA

Income Tax : CBDT vide notification No. 18/2021-Income Tax, Dated: March 16, 2021 inserted new rule 29BA. Application for grant of certificate ...

March 16, 2021 33498 Views 1 comment Print

S. 40(a)(i) Tax Withholding on ‘Other sum chargeable’ of non residents

Income Tax : For the purpose of making disallowance of other sums chargeable under Section 40(a)(i) of the Income-tax Act, 1961, in the case of...

October 29, 2016 7408 Views 0 comment Print

Relaxation from deduction of tax at higher rate U/s. 206AA

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...

June 24, 2016 14845 Views 1 comment Print

CBDT relaxes conditions for furnishing of Form 15CA & Form 15CB

Income Tax : Notification No. 93/2015 - Income Tax G.S.R. 978(E) dated 16th December, 2015 A CA certificate in Form No. 15CB will be required t...

December 16, 2015 187369 Views 28 comments Print


All overseas payments are subject to withholding tax, whether or not the income is taxable : Karnataka High Court

December 2, 2009 8328 Views 0 comment Print

Due to recent ruling of Karnataka High Court order, all overseas payments will now be subject to withholding tax, whether or not the income is taxable. Not only is this in dramatic contrast to previous High Court decisions, it’s also a judgment that will lead to higher cost of business, increased uncertainty and maybe even more litigation—at least for a while.

Bombay HC dismissed the SABMiller writ petition on the ground of decision in Vodafone

May 11, 2009 1315 Views 0 comment Print

Citing the Supreme Court order in the Vodafone case, the Bombay High Court today dismissed the SABMiller writ petition against a showcause notice issued by the Income Tax Department. CNBC-TV18’s Ashwin Mohan reports on how this matter is similar to the Vodafone case? This case is similar to the Vodafone tax tussle. The Income Tax Department order on Vodafone is still pending.

Where income is shared by two or more persons, credit for withholding tax is to be shared in same ratio

March 25, 2009 837 Views 0 comment Print

In a recent ruling in the case of Punjab Financial Corporation (“the assessee”)1, the Punjab and Haryana High Court (“the Court”) held that credit for withholding tax (“WHT”) would be available in the same proportion in which the parties share the income under the provisions of section 1992 of the Income Tax Act, 1961 (the “Act”).

Tax Sword Looms Large On Cross-Border Acquisitions

December 21, 2008 556 Views 0 comment Print

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.

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