![‘Cost Recharge’ Not Taxable as FTS under Indo-UK Treaty: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/01/Cost-Recharge-Taxable-FTS-FTS-under-Indo-UK-Treaty-Indo-UK-Treaty-ITAT-Income-Tax-taxscan.jpg "‘Cost Recharge’ Not Taxable as FTS under Indo-UK Treaty: ITAT [Read Order]")
‘Cost Recharge’ Not Taxable as FTS under Indo-UK Treaty: ITAT [Read Order]
The Mumbai bench of Income Tax Appellate Tribunal (ITAT) has recently held that cost charges are not taxable as Fee for technical service under Indo...
![Mere Securing a House on Rent in USA is not conclusive fact that Assessee is US Resident to Allow DTAA Benefit: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/01/House-on-Rent-DTAA-US-Resident-DTAA-Benefit-ITAT-income-tax-taxscan.jpg "Mere Securing a House on Rent in USA is not conclusive fact that Assessee is US Resident to Allow DTAA Benefit: ITAT [Read Order]")
![Activities by Liaison Office proprietary in Nature, not PE under India Switzerland DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/01/Liaison-Office-proprietary-Liaison-Office-PE-India-Switzerland-DTAA-ITAT-Income-Tax-taxscan.jpg "Activities by Liaison Office proprietary in Nature, not PE under India Switzerland DTAA: ITAT [Read Order]")
![Delay in filing Form 67 not a reason to deny claim of Foreign Tax Credit under DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/01/Form-67-Delay-in-filing-Form-67-filing-Form-67-Foreign-Tax-Credit-DTAA-ITAT-taxscan.jpg "Delay in filing Form 67 not a reason to deny claim of Foreign Tax Credit under DTAA: ITAT [Read Order]")
Business support services is not ‘Technical service’ as ‘make available’ clause not satisfied under DTAA: ITAT deletes addition [Read Order]
The Mumbai bench of Income Tax Appellate Tribunal ( ITAT ) deleted the addition made by the Assessing Officer (AO) stating addition made on account of fee for technical services is unsustainable. ...
![Business support services is not ‘Technical service’ as ‘make available’ clause not satisfied under DTAA: ITAT deletes addition [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/01/Business-support-services-services-Business-Technical-service-DTAA-ITAT-taxscan.jpg "Business support services is not ‘Technical service’ as ‘make available’ clause not satisfied under DTAA: ITAT deletes addition [Read Order]")
Rule 128(9) Disallowing FTC in case of Delay in filing Form 67 Contrary to Indo-USA DTAA, Shall be Read Down: ITAT [Read Order]
The Hyderabad bench of the Income Tax Appellate Tribunal (ITAT) has held that Rule 128(9) of the Income Tax Rules regarding the disallowance of foreign tax credit (FTC) in cases where filing Form 67...
![Rule 128(9) Disallowing FTC in case of Delay in filing Form 67 Contrary to Indo-USA DTAA, Shall be Read Down: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/01/FTC-case-of-Delay-filing-Form-67-Form-67-Indo-USA-DTAA-ITAT-Income-Tax-taxscan-.jpg "Rule 128(9) Disallowing FTC in case of Delay in filing Form 67 Contrary to Indo-USA DTAA, Shall be Read Down: ITAT [Read Order]")
Income Tax penalty levied u/s 271(1)(C) not attract as TDS already deducted under DTAA: ITAT [Read Order]
Income Tax Appellate Tribunal ( ITAT ) of Chandigarh bench ruled that the penalty under section 271(1)(c) does not attract as the Tax Deduction Source (TDS) already deducted under Double Taxation...
![Income Tax penalty levied u/s 271(1)(C) not attract as TDS already deducted under DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/12/Income-Tax-penalty-Income-Tax-penalty-Tax-TDS-DTAA-Taxscan.jpg "Income Tax penalty levied u/s 271(1)(C) not attract as TDS already deducted under DTAA: ITAT [Read Order]")
Guarantee Commission is not Taxable in India under India Germany DTAA: ITAT directs AO to delete Transfer Pricing Adjustment [Read Order]
The Income Tax Appellate Tribunal (ITAT), Mumbai Bench directed Assessing Officer (AO) to delete transfer pricing adjustment and held that Guarantee commission is not taxable in India as per India...
![Guarantee Commission is not Taxable in India under India Germany DTAA: ITAT directs AO to delete Transfer Pricing Adjustment [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/12/Guarantee-Commission-Taxable-in-India-under-India-Germany-DTAA-ITAT-AO-TAXSCAN.jpg "Guarantee Commission is not Taxable in India under India Germany DTAA: ITAT directs AO to delete Transfer Pricing Adjustment [Read Order]")
Amount in Nature of Debt Claim, till possession was actually handed over is Taxable under India UK DTAA: ITAT [Read Order]
The Chandigarh Bench of the Income Tax Appellate Tribunal (ITAT), ruled that amount in nature of debt claim till possession of was actually handed over is taxable under India-UK Double Taxation...
![Amount in Nature of Debt Claim, till possession was actually handed over is Taxable under India UK DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/12/Amount-in-Nature-of-Debt-Claim-Taxable-under-India-UK-DTAA-ITAT-TAXSCAN.jpg "Amount in Nature of Debt Claim, till possession was actually handed over is Taxable under India UK DTAA: ITAT [Read Order]")
No Profits attributable to PE if it records a Global Net Loss: Delhi HC grants relief to Nokia [Read Order]
In a recent judgment pronounced by Delhi High Court, chaired by Justice Rajiv Shakedhar and Justice Tara Vitasta Ganju, upheld the decision of the Income Tax Appellate Tribunal (ITAT) that the...
![No Profits attributable to PE if it records a Global Net Loss: Delhi HC grants relief to Nokia [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/12/Global-Net-Loss-Delhi-High-Court-PE-Permanent-Establishment-Nokia-relief-to-Nokia-taxscan-.jpg "No Profits attributable to PE if it records a Global Net Loss: Delhi HC grants relief to Nokia [Read Order]")
IHC is part of Income from Operation of Ships in International Traffic under India- France DTAA, not Taxable: ITAT [Read Order]
The Mumbai Bench of the Income Tax Appellate Tribunal ( ITAT ), held that Inland Haulage Charges (IHC) is part of income from operation of ships in International Traffic under India- France Double...
![IHC is part of Income from Operation of Ships in International Traffic under India- France DTAA, not Taxable: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/12/IHC-Income-Income-from-Operation-Ships-International-Traffic-India-France-DTAA-DTAA-taxable-ITAT-Taxscan.jpg "IHC is part of Income from Operation of Ships in International Traffic under India- France DTAA, not Taxable: ITAT [Read Order]")