Saturday International Tax Gyan!! (SITG No. 243) #taxmadeeasy #taxinpic The PPT is a general anti-avoidance rule applied under DTAAs. PPT in India’s tax treaties states: ‘If it is reasonable to conclude that one of the principal purposes of a transaction or arrangement is to obtain a tax benefit, the tax benefit can be denied, unless …
Saturday International Tax Gyan!! (SITG No. 242) #taxmadeeasy #taxinpic Part 3 – Taxpayer can opt for taxability under Act or DTAA, whichever is more beneficial for each stream of income.
Saturday International Tax Gyan!! (SITG No. 241) #taxmadeeasy #taxinpic Part- 2 of a new series “Back to Basic Principles” wherein we shall discuss some basic principles of DTAA read with Income tax act. As per the established principle, in cases where two views are possible, view which is favourable to taxpayer should be adopted.
Saturday International Tax Gyan!! (SITG No. 240) #taxmadeeasy #taxinpic As per the established principle, in cases where a DTAA is in force, the provisions of the Act or the DTAA, whichever are more beneficial to the assessee, shall prevail.
Saturday International Tax Gyan!! (SITG No. 239) #taxmadeeasy #taxinpic PE must be treated as a distinct and independent entity for taxation purposes. Profits attributable to a PE are taxable irrespective of the global financial performance of the enterprise. {Hyatt International Southwest Asia Ltd. vs ADIT [2024] 166 taxmann.com 466 (Delhi)[19-09-2024]}
Tungsten Network Ltd Vs DCIT ITA Nos. 2237 & 2238/Del/2024 [18-12-2024] Payment for cloud-based and digital service providers will be covered under definition of “technical services” and are taxable on the basis of source rule and utilization of services.
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“
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 »
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 …
FTC credit not dependent on filing of tax return in foreign jurisdiction Read More »
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
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