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In a ruling in favour of Mitsubishi Corporation India P Ltd, the Delhi High Court ruled that disallowance under section 40(a)(i) of the Income Tax Act, 1961 does not apply concerning the provision of Double Taxation Avoidance Agreements (DTAAs) entered into by India with Japan and the USA. The order passed by the ITAT is […]
The recent ruling from the Income Tax Appellate Tribunal (ITAT) in the matter between Amit Laroya and ACIT (ITAT Delhi) carries significant implications for the taxation of salary income earned by a Korean resident for services provided outside of India. The central issue revolves around the interpretation of Article 15(1) of the India-Korea Double Taxation […]
The Bangalore Bench of the Income Tax Appellate Tribunal (ITAT) ruled that interconnectivity utility charges (IUC) could not be levied to tax as royalty under the India-Austria Double Taxation Avoidance Treaty (DTAA). The bench of Beena Pillai (Judicial Member) and Chandra Poojari (Accountant Member) witnessed that payments that the taxpayer obtained for interconnectivity utility levies […]
A Chandigarh bench of the ITAT ruled that the penalty under section 271(1)(c) does not apply because tax has already been deducted in accordance with Double Taxation Avoidance Agreements (DTAA). As a short summary, the facts are that the assessee is not a resident of the country and has booked certain units in the entity […]
The status of the residential person poses an essential role in finding out the method of his or her income that shall come under the tax for that year in India. Moreover, non-resident Indians NRIs and Persons of Indian Origin (PIOs) are very careful in preparing their stay in India for the specific year so […]
The expense for the management and marketing support services paid to foreign companies is not levied to tax under Fee for Technical Service (FTS) under the India-Netherlands Double Taxation Avoidance Agreement (DTAA) and therefore TDS is not deductible under section 195 of the Income Tax Act, ITAT Delhi ruled. Facts About the Case of NTL […]
A recent survey has depicted the complexities of tax compliance for NRIs and OCIs. India has the world’s largest overseas diaspora, with nearly 32 million NRIs and OCIs. India’s NRI network witnesses an effective presence in Gulf countries, alongside Singapore, the US, Canada, the UK, and more. SBNRI surveyed a comprehensive investment platform for NRIs […]
As a fee for technical services (FTS) business support services are not liable for tax, and no TDS is accountable to be deducted, The Bombay High Court ruled. The bench of Justice K. R. Shriram and Justice Neela Gokhale noted that even if it is fees for technical or consultancy services, it can be just […]
Delhi High Court judgment in the case of CIT Vs S.A. Chitra Ventures Ltd. specifies the jurisdiction of Assessing Officers (AOs) in passing draft assessment orders. The ruling of the court specifies the restrictions on AO’s authority in the absence of any variation in income or loss. Detailed Analysis in the Case of S.A. Chitra […]
