Income Tax : Delhi HC rules reimbursements to NRAEs not subject to TDS as "fees for technical services," clarifying scope of Section 9(1)(vii) ...
Income Tax : Countrywise withholding tax rates as per the Income Tax Act compared to tax treaties/DTAA. Understand differences & implications f...
Income Tax : Withholding tax rates for dividends, interest, royalties and Fee for Technical Services in different countries. Understand how tax...
Income Tax : Understand TDS provisions for buyers and sellers in the sale of property in India by an NRI. Get insights into tax rates, implicat...
Income Tax : Learn about Form 15CA and 15CB: Crucial for foreign remittances and tax compliance. A complete guide for taxpayers....
Income Tax : 20% Withholding Tax Rate on profits distributed by unlisted companies to shareholders through buy-back of shares Existing provisio...
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...
Income Tax : The government will look into more cross-border mergers involving Indian assets, like the Vodafone-Hutchison deal, after the Bomba...
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...
Income Tax : The cost of doing business in India could come down if the dividend distribution tax (DDT) levied on foreign shareholders is repla...
Income Tax : ITAT Delhi rules that remittances to foreign subsidiaries are not taxable in India, leading to the cancellation of tax penalties o...
Income Tax : Supreme Court dismisses IT Dept's petition, ruling Vodafone Idea isn't liable to deduct TDS on payments to non-resident telecom op...
Income Tax : In a landmark ruling, Delhi High Court quashes TDS penal action against DLF Homes Panchkula Pvt Ltd for the FY 2013-14. Detailed v...
Income Tax : ITAT held that payment made to non-resident without deducting the tax at source u/s. 195 of the Act, does not come under the provi...
Income Tax : Assessee was not having any permanent establishment in India and was providing the service only from Singapore and therefore the p...
Income Tax : CBDT vide notification No. 18/2021-Income Tax, Dated: March 16, 2021 inserted new rule 29BA. Application for grant of certificate ...
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...
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...
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...
The Hon’ble Supreme Court on 2nd March 2021 in the case of Engineering Analysis Centre of Excellence Private Limited Vs CIT, put a rest to the contentious issue of tax on Payment by end users or tech companies in India to suppliers abroad on import of software as ‘Royalty’. Let’s understand what was the issue […]
Jitendra Sharma Vs JCIT (Intl Taxation) (ITAT Indore) ITAT Indore held that no penalty under Section 271C to be levied for deduction of tax under Section 194IA @1% instead of Section 195 @ 20.6% on purchase of property from Non Resident. FULL TEXT OF THE ITAT JUDGEMENT The above captioned appeals filed at the instances […]
The issue under consideration is whether income tax levied on revenue received from IDC agreement, management agreement, and referral agreement as per the India-Singapore DTAA?
The issue under consideration is whether as per India-Mauritius DTAA, Interest Income from Foreign Currency loan and Securities would be eligible to tax in India?
To Whom does Section 195 applies? a) A resident Making Payment to Non-Resident and, b) A Non-Resident making payment to a Non-resident. As per Section 195, it says Any person responsible for paying to non-resident…any person not only includes Resident but also non-resident making payment to a non-resident
The new rules for preparation, filing/ issuing forms 15CA and 15CB are effective from 01st April’2016. With these new rules coming into effect significant changes have come into effect for furnishing forms 15CA & 15CB. Some of the key changes for furnishing form 15CA & 15CB that have come into effect from 01st April’2016 are:
Withholding taxes u/s 195 in respect of transactions with Non-Residents has always been a bone of contention between Assessee and tax authorities. Though liability for deduction of TDS is clear in respect of some transactions like royalties, fees for technical services, interest etc.,
whether the assessee has to deduct tax at source at the rates prescribed in section 206AA in case the payees are unable to furnish their PANs, even if tax liability arises out of the treaty?
SPX India Pvt. Ltd. Vs CIT (ITAT Delhi) Tax was required to be deducted at source on share of ISO audit expenses paid to foreign parent company, as element of income was embedded in receipt of auditor. FULL TEXT OF THE ITAT JUDGEMENT Assessee is in appeal before us against the order of ld. CIT […]
Bureau Veritas-Indian Division Vs ADIT (ITAT Mumbai) Technical expenses allocated by head office to assessee-Indian division was in nature of reimbursement of technical expenses to head office and not on account of any specific technical services having been ‘made available’ and, therefore, such amount could not be brought to tax in hands of assessee under […]