Relationship Between DTAAs And Domestic Law
INTRODUCTION International trade has existed since the birth of nations, but there has been an accelerating growth not only in trade but also in...
![Receipt from Support Services cannot be Treated as FIS under Article 12(4)(b) of India -USA DTAA: ITAT Deletes Income Tax Addition [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/10/Receipt-from-Support-Services-Treated-as-FIS-under-India-USA-DTAA-ITAT-Income-Tax-TAXSCAN.jpg "Receipt from Support Services cannot be Treated as FIS under Article 12(4)(b) of India -USA DTAA: ITAT Deletes Income Tax Addition [Read Order]")
![DTAAs not to be Enforced without Central Govt. Notification u/s 90 of Income Tax Act: Supreme Court in MFN Case [Read Judgement]](https://www.taxscan.in/wp-content/uploads/2023/10/DTAAs-Enforced-without-Central-Govt-Notification-Income-Tax-Act-Supreme-Court-in-MFN-Case-TAXSCAN.jpg "DTAAs not to be Enforced without Central Govt. Notification u/s 90 of Income Tax Act: Supreme Court in MFN Case [Read Judgement]")
Consultancy Services cannot be Treated as FIS Merely because Service Provider has used Substantial Technical Skill as per India-USA DTAA: ITAT [Read Order]
The Delhi Bench of Income Tax AppellateTribunal (ITAT) has held that the consultancy services could not be treated as Fee for Included Services (FIS) merely because the service provider has used...
![Consultancy Services cannot be Treated as FIS Merely because Service Provider has used Substantial Technical Skill as per India-USA DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/Consultancy-Services-Treated-FIS-Merely-Service-Provider-Substantial-Technical-Skill-India-USA-DTAA-ITAT-taxscan.jpg "Consultancy Services cannot be Treated as FIS Merely because Service Provider has used Substantial Technical Skill as per India-USA DTAA: ITAT [Read Order]")
Supreme Court upholds Income Tax Exemption granted on Dividend Income to Multi-State Cooperative Society with PE in Oman as per India-Oman DTAA [Read Order]
The Supreme Court has recently ruled that when an Indian entity's establishment operates in Oman and holds a 'Permanent Establishment' status under the Double Taxation Avoidance Agreement (DTAA), any...
Salary Accrued for Work Performed in Foreign Jurisdiction is not Taxable but Salary Received for Work Performed in India would be Taxable: ITAT Allows Benefits under India-China DTAA [Read Order]
The Chennai Bench of Income Tax Appellate Tribunal (ITAT) held that salary income as accrued to the assessee for work performed in a foreign jurisdiction would not be taxable in India whereas the...
![Salary Accrued for Work Performed in Foreign Jurisdiction is not Taxable but Salary Received for Work Performed in India would be Taxable: ITAT Allows Benefits under India-China DTAA [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/Salary-Accrued-for-Work-Performed-Salary-Accrued-Foreign-Jurisdiction-Salary-Received-for-Work-Performed-in-India-ITAT-Allows-Benefits-under-India-China-DTAA-Salary-Received-India-China-DTAA-taxscan.jpg "Salary Accrued for Work Performed in Foreign Jurisdiction is not Taxable but Salary Received for Work Performed in India would be Taxable: ITAT Allows Benefits under India-China DTAA [Read Order]")
Capital Gain Derived by Sale of Equity Shares not Taxable in terms of Article 13(4) of India-Mauritius DTAA: ITAT [Read Order]
The Delhi Bench of Income Tax Appellate Tribunal (ITAT) has held that the capital gain derived by the sale of equity shares is not taxable in terms of Article 13(4) of the India Mauritius Double...
![Capital Gain Derived by Sale of Equity Shares not Taxable in terms of Article 13(4) of India-Mauritius DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/ITAT-capital-Gain-Capital-Gain-Derived-by-Sale-of-Equity-Equity-India-Mauritius-DTAA-taxscan.jpg "Capital Gain Derived by Sale of Equity Shares not Taxable in terms of Article 13(4) of India-Mauritius DTAA: ITAT [Read Order]")
Income from sub licensing software for healthcare business in India Shall not be taxed as Business Income under India – USA DTAA due to absence of PE: ITAT [Read Order]
The Income Tax Appellate Tribunal (ITAT) Delhi bench held that the Income from sub licensing software for the healthcare business in India should not be taxed under Business Income due to...
![Income from sub licensing software for healthcare business in India Shall not be taxed as Business Income under India – USA DTAA due to absence of PE: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/Income-sub-licensing-software-healthcare-business-India-Business-Income-India-USA-DTAA-PE-ITAT-TAXSCAN.jpg "Income from sub licensing software for healthcare business in India Shall not be taxed as Business Income under India – USA DTAA due to absence of PE: ITAT [Read Order]")
Income received from India by way of Royalties shall be taxed in India only on receipt basis under Indo-Switzerland DTAA: ITAT grants relief to ABB Switzerland [Read Order]
The Income Tax Appellate Tribunal (ITAT) Bangalore bench while granting relief to ABB Switzerland held that income received from India by way of Royalties should be taxed in India only on...
![Income received from India by way of Royalties shall be taxed in India only on receipt basis under Indo-Switzerland DTAA: ITAT grants relief to ABB Switzerland [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/received-India-Royalties-taxed-India-receipt-Indo-Switzerland-DTAA-ITAT-ABB-Switzerland-TAXSCAN.jpg "Income received from India by way of Royalties shall be taxed in India only on receipt basis under Indo-Switzerland DTAA: ITAT grants relief to ABB Switzerland [Read Order]")
Receipts from Reselling of Hardware and software packages are not 'Royalty' under India-Singapore DTAA: ITAT [Read Order]
The Income Tax Appellate Tribunal (ITAT) Delhi bench held that receipts from reselling of hardware and software packages are not “Royalty” under India Singapore Double Taxation Avoidance Agreement. ...
![Receipts from Reselling of Hardware and software packages are not Royalty under India-Singapore DTAA: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/08/Receipts-Reselling-Hardware-software-packages-Royalty-India-Singapore-DTAA-ITAT-TAXSCAN.jpg "Receipts from Reselling of Hardware and software packages are not Royalty under India-Singapore DTAA: ITAT [Read Order]")