Tag: dtaa
CBDT issues clarification on Circular No. 01/2025 On Application of PPT under India’s DTAAs CBDT has issued Circular No. 01/2025 dated 21.01.2025 as a guidance to provide clarity and certainty on the application of the Principal Purpose Test (PPT) provision under India’s Double Taxation Avoidance Agreements (DTAAs). It …
Guidance for application of the Principal Purpose Test (PPT) under India’s Double Taxation Avoidance Agreements CBDT has issued Circular No. 1/2025 dated 21.01.2025 as Guidance for application of the Principal Purpose Test (PPT) under India’s Double Taxation Avoidance Agreements The Multilateral Convention to Implement Tax Treaty Related Provisions …
Bonafide belief that TDS was deducted and no additional tax was payable accepted by ITAT In a recent judgment, ITAT Mumbai has held that the submissions of the assessee, that she was under a bonafide belief that the tax at source was deducted properly and no additional tax …
Income Tax relief u/s 90 for tax paid in a foreign country can not be denied for mere delay in filing Form No. 67 as the provision not mandatory but directory- ITAT ABCAUS Case Law Citation:ABCAUS 3747 (2023) (05) ITAT Important Case Laws relied upon:Hertz Software India (P.) …
IT support services do not satisfy make available test under India-UK DTAA ABCAUS Case Law CitationABCAUS 3627 (2022) (12) ITAT Important Case Laws relied upon:CIT Vs. Guy Carpenter & Co. Ltd 254 CTR 243H.J. Heinz CompanyDe Beers India Minerals Limited 346 ITR 467Mitsubishi Electric India Ltd ITA No. …
CBDT issues Clarification regarding the Most-Favoured-Nation (MFN) clause in the Protocol to India’s DTAAs with certain countries F.No.S03/1/2021-FT&TR-I Government of India Ministry of Finance Department of Revenue Central Board of Direct Taxes (FT&TR-I) Circular No. 3/2022 New Delhi, 3rd February, 2022 Subject: Clarification regarding the Most-Favoured-Nation …
No TDS requirement u/s 195 on employee secondment agreement for payments for reimbursement to a non resident enterprises towards costs of seconded employees. ABCAUS Case Law CitationABCAUS 3432 (2020) (12) HC Important case law relied upon by the parties:M/s Centrica India offshore Pvt. Ltd. vs. Commissioner of income …
Assessee entitled to tax credit u/s 91 of both federal and state taxes paid by him. Benefit also available to not ordinarily resident Indians ABCAUS Case Law CitationABCAUS 3390 (2020) (09) ITAT Important case law relied upon by the parties:Wipro Ltd vs Deputy Commissioner of Income Tax
Mutual Agreement Procedure (MAP) Guidance notes released by CBDT Mutual Agreement Procedure (MAP) The Double Taxation Avoidance Agreements (DTAAs or Tax Treaties) provide rules and mechanisms for allocation of taxing rights amongst the treaty partners; avoidance of economic and juridical double taxation; and resolution of taxation not in …
Project office used as auxiliary office for liaison not a PE unless core business is carried on therefrom – SC ABCAUS Case Law Citation:ABCAUS 3339 (2020) (07) SC Important case law relied upon by the parties:Commissioner of Income Tax and Another v. Hyundai Heavy Industries Co. Ltd., (2007) …
