Reclassification of FPI to FDI
Dear all, This time we have come up with an interesting FEMA Provisions relating to “Reclassification of Foreign Portfolio Investment to Foreign Direct Investment ” #FEMAkeFUNDAE #FamiliarwithFEMA #rbi
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Update on MFN Clause with Switzerland
Saturday International Tax Gyan!! (SITG – 237) #taxmadeeasy #taxinpic “Switzerland has revoked its unilateral statement and now both the countries share the same understanding about MFN clause“
Warehouse payment will not be considered as payment for FTS under section 9(1)(vii)
Saturday International Tax Gyan!! (SITG – 236) #taxmadeeasy #taxinpic Avtec Ltd. vs ACIT [2024] 168 taxmann.com 692 (Delhi – Trib.) [29.11.2024] “Payments for warehousing services are logistical in nature and do not qualify as ‘Fees for Technical Services’ (FTS) under Section 9(1)(vii) of the Income Tax Act or DTAA, as they do not ‘make available’ …
Warehouse payment will not be considered as payment for FTS under section 9(1)(vii) Read More »
Form LLP 2
Dear all,This time we have come up with an interesting FEMA Provisions relating to “Form LLP II” FEMAkeFUNDAE FamiliarwithFEMA #rbi
FTC credit not dependent on filing of tax return in foreign jurisdiction
Saturday International Tax Gyan!! (SITG – 235) #taxmadeeasy #taxinpic Amarchand Mangladas & Suresh A Shroff & Co. vs ACIT [2024] ITA No.852/M/2024 [30-09-2024] Filing tax return is not mandatory for FTC eligibility as taxes withheld abroad qualifies as taxes paid and allowed full FTC to prevent double taxation, in line with DTAA provisions and established …
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Portfolio Investment Scheme for NRIs
Dear all, This time we have come up with an interesting FEMA Provisions relating to “Portfolio Investment Scheme for NRIs” #FEMAkeFUNDAE #FamiliarwithFEMA #rbi
Capital Gain from mutual fund in case of UAE resident not taxable in India
Saturday International Tax Gyan!! (SITG – 234) #taxmadeeasy #taxinpic Saket Kanoi Vs DCIT [2024] 168 taxmann.com 418 (Delhi – Trib.)[23-10-2024] UAE resident earning capital gain income from mutual fund in India will only be taxable in UAE and not in India
Third Party Export Payment
Dear all, This time we have come up with an interesting FEMA Provisions relating to “Third Party Export Payment” #FEMAkeFUNDAE #FamiliarwithFEMA #rbi
Salary earned outside India by non-resident is not taxable in India
Saturday International Tax Gyan!! (SITG – 233) #taxmadeeasy #taxinpic Sanjay Ajit vs Income-tax Officer (International Taxation) [2024] 166 taxmann.com 629 (Chennai – Trib.) Salary earned for project done outside India will not be taxable in India for a non resident irrespective of whether the tax paid outside India was borne by assessee or not