Foreign Tax Credit is allowed even if Form 67 is not Filed: Hertz Software India Private Limited vs Asst(CIT)

The assessee has filed an appeal against the order dated 18/03/2020 passed by the Ld. CIT(A)-3, Bangalore for the assessment year 2017-18. The grounds for appeal are as follows: Grounds of Appeal: Brief facts of the case are as under: The company in question is a private limited company operating in the software publishing, consultancy …

Claim Foreign Tax Credit by filing Form 67 Online: Pradeep Lankapalli, Bangalore vs Deputy Commissioner Of Income

The appeal is filed by the assessee against the order dated 26.07.2021 passed by the Commissioner of Income-tax Appeals (CIT(A)) in a faceless appeal. The grounds of appeal are as follows: The appellant reserves the right to add, alter, rescind, or modify the grounds or present further documents, facts, or evidence before or during the …

Lower Deduction TDS Certificate For NRI  | TDS on Immovable on Selling of Property by NRI

Property sale by Non-Resident Indians (NRIs) and Overseas Citizen of India (OCIs) in India is a common transaction. In this regard, NRIs often seek various tax and legal services related to the sale of their property. One of the first services NRIs look for is obtaining a Lower TDS Certificate or Nil TDS deduction Certificate …

Tax planning, Tax Avoidance, and Tax Evasion

Tax planning, tax avoidance, and tax evasion are all related to the payment of taxes, but they represent different approaches and have distinct legal implications. Tax planning refers to the process of legally reducing the amount of tax that a person or company is required to pay. Tax avoidance refers to the legal use of …

Depreciation cannot be denied simply because the cars are registered in the name of the company’s Directors, as long as the dominion ownership test is met.

In the assessment year 2009-10, the Assessee-Company purchased 5 cars, including Audi and BMW, and registered them in the name of the Directors. The company claimed depreciation for these cars but the Revenue denied the depreciation of 2 cars on the ground that the Assessee failed to furnish the logbooks. The Revenue had an apprehension …

Filing Form 67 is Not Mandatory for Claiming Foreign Tax Credit in ITR

In the recent case of Brinda Rama Krishna v. ITO, the Bangalore Income Tax Appellate Tribunal (ITAT) allowed the assessee’s appeal and held that the requirement to furnish Form No. 67 was directory and that Rule 128 did not provide for the disallowance of foreign tax credit (FTC) on the non-furnishing of Form No. 67 …

Salary Earned from a US Employer is Not Taxable in India

The Kolkata Income Tax Appellate Tribunal (ITAT) has ruled in favor of an assessee, who had appealed against the order of the lower authorities, and held that the salary earned from a US employer is not taxable in India in view of Article 16 of the India-US Double Taxation Avoidance Agreement (DTAA). The assessee, an …

The Pros and Cons of Using a Tax Haven Countries

The use of tax havens has been a controversial topic for many years, with both supporters and critics of the practice having valid arguments. Tax havens are defined as countries or territories that offer low or no taxes on certain types of income or transactions, as well as strict financial privacy laws. These features make …

The Top Tax Haven Countries for Wealthy HNI Individuals and Corporations | Tax Haven Countries

A tax haven is a country or territory that offers low or no taxes to foreign individuals or businesses. These countries typically have lenient tax laws and regulations and offer secrecy and confidentiality to those who use their services. Tax havens have been around for centuries, but have become increasingly popular in recent years due …

What is Transfer Pricing: Its Purpose and Various Methods

Transfer pricing refers to the practice of setting prices for goods and services exchanged between related parties, such as subsidiaries of multinational companies. The purpose of transfer pricing is to ensure that the prices of these transactions are similar to those that would be charged by unrelated parties in comparable transactions, in order to prevent …

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