A tax treaty, also known as a double tax treaty or a tax agreement, is a bilateral agreement between two countries that aims to prevent double taxation of income earned by residents of one country in the other country. It establishes the rules for taxing different types of income, such as wages, dividends, and capital …
Continue reading “What is Tax Treaty and How Treaty Benefits To Non-Resident Indians (NRIs)”
As a salaried individual who has foreign income, receiving an income tax notice can be a daunting experience. However, it’s essential to understand that foreign income is subject to taxation in your home country, just like your domestic income. If you’ve received an income tax notice for your foreign income, the first step is not …
The ITAT in Jaipur recently dismissed the Revenue’s appeal and held that the Assessee, an individual service provider of online advertisement, digital marketing and web design for consultancy charges, was not liable for disallowance under Section 40(a)(ib) of the Income Tax Act, 1961. The Assessee was initially subjected to disallowance of Rs. 8.89 Crore for …
In the recent case of PCIT v. Boeing India (P) Ltd. (2023) 146 taxmann.com 131 (Del.), the issue at hand was whether the foreign company, who had deputed one of its employees to look after the affairs of the Indian company, was liable for tax under Section 195 of the Act, once the nature of …
The issue of whether the salary of a non-resident seafarer, which was earned for services rendered outside of India, would be included in the total income of the assessee is a matter of legal concern. Despite the fact that the assessee mistakenly indicated that the salary had accrued in India while filing their income tax …
The Mumbai ITAT has ruled in favor of the assessee, holding that the liaison office (LO) of a Swiss company’s subsidiary in India does not qualify as a permanent establishment (PE). As a result, the addition of business income of Rs. 1.50 crore, attributed to 50% of the income from repairs and maintenance and integrated …
The Bangalore ITAT has upheld the expenses incurred by the assessee-company, Honeywell Technology Solutions (P) Ltd, for the assessment year 2011-12. The company, engaged in the business of software development and IT enabled services, incurred a total of Rs. 32.87 crore on the maintenance of computer licenses, purchase of software, legal and professional charges, and …
The ITAT in Bangalore has recently issued a judgement in the case of Biplab Adhya v. ITO, related to the assessment year 2019-20. In this case, the Assessee, an individual and a non-resident, filed their income tax return declaring an income of Rs. 3,16,670, which was subject to scrutiny. During the assessment, the Assessing Officer …
The Mumbai Income Tax Appellate Tribunal (ITAT) has recently ruled that the income received from domain name registration services provided by a Registrar authorized by the Internet Corporation for Assigned Names and Numbers (ICANN) is not taxable as royalty in India, as long as there is no intellectual property right in the form of a …
The Delhi ITAT has ruled on the issue of residency under the India-Singapore Double Taxation Avoidance Agreement (DTAA) in the case of Sameer Malhotra v. ACIT. The case involved a dispute over the taxation of the Assessee’s income from employment in India and Singapore for the Assessment Year 2015-16. The Assessee initially offered to pay …
