Blog, News, International Tax May 20, 2022 AO can’t import ‘beneficial ownership’ under Article 13 of Indo Mauritius DTAA: ITAT Case Details: Blackstone FP Capital … Continue reading “AO can’t import ‘beneficial ownership’ under Article 13 of Indo Mauritius DTAA: ITAT”
Blog, International Tax November 1, 2022 Taxation of Expatriate Employees | Secondment | Cross Border Movement Table of Contents Introduction What … Continue reading “Taxation of Expatriate Employees | Secondment | Cross Border Movement”
News, Blog, International Tax March 28, 2022 Business support service is tax exempt applying MFN clause under India-Belgium tax treaty Shailendra Sharma – [2022] 136 … Continue reading “Business support service is tax exempt applying MFN clause under India-Belgium tax treaty”
Blog, News, International Tax March 10, 2022 Claim of FTC can’t be disallowed just because Form no. 67 wasn’t filed by due date: ITAT Case Details: Ms. Brinda RamaKrishna … Continue reading “Claim of FTC can’t be disallowed just because Form no. 67 wasn’t filed by due date: ITAT”
Blog, News, International Tax March 5, 2022 Sec. 44BB applies to charter hire charges received by NR for transporting equipment from yard to offshore sites: HC Case Details: Larsen & Toubro … Continue reading “Sec. 44BB applies to charter hire charges received by NR for transporting equipment from yard to offshore sites: HC”
Blog, News, International Tax February 26, 2022 Term ‘Process’ defined by section 9 can’t be imported to interpret ‘secret formula or process’ used in DTAA: ITAT Case Details: ACIT v. Viacom … Continue reading “Term ‘Process’ defined by section 9 can’t be imported to interpret ‘secret formula or process’ used in DTAA: ITAT”
Blog, News, International Tax February 25, 2022 ‘Make Available’ clause is not satisfied if NR services are repetitive in nature Case Details: GE Energy Management … Continue reading “‘Make Available’ clause is not satisfied if NR services are repetitive in nature”
Blog, News, International Tax February 15, 2022 Sum recovered from Indian affiliate for software used to provide services to various group entities is royalty: ITAT Case Details: Rieter Machine Works … Continue reading “Sum recovered from Indian affiliate for software used to provide services to various group entities is royalty: ITAT”
Blog, News, International Tax February 9, 2022 No PE exists if ESPN India rendering support services to enable NR to render services to their clients abroad: ITAT Case Details: ESPN Star Sports … Continue reading “No PE exists if ESPN India rendering support services to enable NR to render services to their clients abroad: ITAT”
News, Blog, International Tax January 28, 2022 No denial of nil TDS certificate just because group Co. of assessee involved in tax evasion in similar transaction: HC Case Details: Celestial Aviation Trading … Continue reading “No denial of nil TDS certificate just because group Co. of assessee involved in tax evasion in similar transaction: HC”