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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 615 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 1050 Views 0 comment Print

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

Income Tax : Detailed comparison of dividend, interest, royalty, and FTS withholding tax rates between India's Income-tax Act and over 60 Doubl...

October 19, 2025 43012 Views 1 comment Print

Countrywise Withholding Tax Rates / Chart as per DTAA

Income Tax : An analysis of Double Taxation Avoidance Agreement (DTAA) withholding tax rates across various countries for dividends, interest, ...

October 17, 2025 450503 Views 28 comments Print

TDS on Non-Resident Payments: Section 195 Analysis

Income Tax : In-depth analysis of Section 195 TDS on payments to non-residents, covering taxability, DTAA interaction, PAN rules (206AA), Form ...

September 25, 2025 9561 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 1752 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 943 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 1163 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 1355 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 3029 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 210 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 369 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 459 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 1293 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 480 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 33273 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 7321 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 14752 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 187048 Views 28 comments Print


No Section 40(a)(i) Disallowance for Purchases from Foreign AEs without PE in India: Delhi HC

September 15, 2025 603 Views 0 comment Print

Delhi High Court rules purchases from foreign AEs without a PE are not taxable in India, preventing Section 40(a)(i) disallowance and upholding DTAA non-discrimination clauses.

TDS Not Deductible on Foreign Bandwidth, 80G allowed on CSR Donation

August 8, 2025 516 Views 0 comment Print

ITAT Mumbai holds that payments for foreign bandwidth do not attract TDS; also upholds deduction u/s 80G for CSR donations not claimed under Section 37.

Cross-Cost Charges Not Royalty, AO to withholding Issue NIL Tax Certificate: Delhi HC

June 17, 2025 435 Views 0 comment Print

Delhi High Court held that payment of cross-cost charges doesn’t construed as royalties within scope of Article 12(3) of the India-US DTAA hence order rejecting application for NIL withholding tax set aside. AO directed to issue necessary certificate.

Reimbursement of Salaries to Seconded Employees Does Not Constitute FTS

March 16, 2025 1920 Views 0 comment Print

Karnataka HC upholds Flipkart’s stance on TDS under Section 195, ruling seconded employees’ salaries as reimbursements, not taxable income for Walmart Inc.

TDS Obligations: Reimbursement of Expenses vs. Fee for Technical Services

September 25, 2024 2424 Views 0 comment Print

Delhi HC rules reimbursements to NRAEs not subject to TDS as “fees for technical services,” clarifying scope of Section 9(1)(vii) and TDS under Section 195.

Tax Deduction Not Required for Remittances to Foreign Subsidiaries: ITAT Delhi

September 5, 2024 936 Views 0 comment Print

ITAT Delhi rules that remittances to foreign subsidiaries are not taxable in India, leading to the cancellation of tax penalties on HCL Technologies Ltd.

Vodafone Idea Not Required to Deduct TDS on Foreign Telecom Charges: SC

August 20, 2024 753 Views 0 comment Print

Supreme Court dismisses IT Dept’s petition, ruling Vodafone Idea isn’t liable to deduct TDS on payments to non-resident telecom operators, following past judgments.

Sale of Property in India by an NRI – TDS provisions for Buyers & Sellers

July 24, 2024 316458 Views 61 comments Print

Understand TDS provisions for buyers and sellers in the sale of property in India by an NRI. Get insights into tax rates, implications, and advice for seamless transactions.

Demystifying Form 15CA and 15CB: A Guide to Foreign Remittances

September 12, 2023 8145 Views 1 comment Print

Learn about Form 15CA and 15CB: Crucial for foreign remittances and tax compliance. A complete guide for taxpayers.

Delhi HC Quashes TDS Penal Action Against DLF

August 1, 2023 2322 Views 0 comment Print

In a landmark ruling, Delhi High Court quashes TDS penal action against DLF Homes Panchkula Pvt Ltd for the FY 2013-14. Detailed verdict here.

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