Income Tax : Detailed comparison of dividend, interest, royalty, and FTS withholding tax rates between India's Income-tax Act and over 60 Doubl...
Income Tax : An analysis of Double Taxation Avoidance Agreement (DTAA) withholding tax rates across various countries for dividends, interest, ...
Income Tax : In-depth analysis of Section 195 TDS on payments to non-residents, covering taxability, DTAA interaction, PAN rules (206AA), Form ...
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 : 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 : 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 : Supreme Court admits appeal by Tesco Bengaluru against CESTAT ruling on reverse charge service tax for seconded overseas employees...
Income Tax : Delhi High Court rules purchases from foreign AEs without a PE are not taxable in India, preventing Section 40(a)(i) disallowance ...
Income Tax : ITAT Mumbai holds that payments for foreign bandwidth do not attract TDS; also upholds deduction u/s 80G for CSR donations not cla...
Income Tax : Delhi High Court held that payment of cross-cost charges doesn’t construed as royalties within scope of Article 12(3) of the Ind...
Corporate Law : Karnataka HC upholds Flipkart's stance on TDS under Section 195, ruling seconded employees' salaries as reimbursements, not taxabl...
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...
Any person responsible for paying to a non-resident, not being a company, or to a foreign company, shall deduct income-tax thereon at the rates in force is responsible to deduct tax u/s 195 of the act. Nature of Payment a) Any interest (not being interest referred to in section 194LB, 194LC and 194LD). b) Any […]
Airports Authority of India Vs ITO(TDS) (ITAT Delhi) Conclusion: TDS under section 195 was not applicable on payments made by company to the Federal Aviation Administration, USA (FAA), for providing technical assistance to AAI by way of providing its personnel and meeting on ATFM requirements and assisting AAI in connection with ATFM by development of […]
Withholding tax rate of 5% is to be applied while making payment of dividend by Indian entity to its shareholder in Netherlands after applying the Most Favoured Nation (MFN) clause in the Tax Treaty between India and Netherlands.
DCIT Vs Force Motors Ltd. (ITAT Pune) During the First Appellate Proceedings before the Ld. CIT(Appeals), it was submitted by the assessee that payments were made to technical consultants from Japan, Germany and Italy. The assessee submitted that these consultants are not residents of India and further their stay in India was less than the […]
CBDT issued notification No. 18/2021-Income Tax, Dated: March 16, 2021 & inserted a New Rule Rule 29BA. The Rule would be effective from 1 April 2021.
CBDT vide notification No. 18/2021-Income Tax, Dated: March 16, 2021 inserted new rule 29BA. Application for grant of certificate for determination of appropriate proportion of sum (other than Salary), payable to non-resident, chargeable in case of the recipients and also released new FORM No. 15E – Application by a person for a certificate under section […]
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?
