Blogarama: The Oldest Blog Directory

ITAT Delhi held that provision of management support services to various hotels in India doesn’t come under Article 12(4) of India -Singapore DTAA. Accordingly, addition unsustainable… Read More

Get insights into the tax obligations of expats in India, the residence-based taxation system, and Double Taxation Avoidance Agreements (DTAA). Understand tax deductions, compliance, and the… Read More

Countrywise withholding tax rates as per the Income Tax Act compared to tax treaties/DTAA. Understand differences & implications for dividends, interest, royalties and technical services… Read More

Delhi High Court held that tax credit could not be extended to the assessee, because it had not paid tax in Thailand, i.e., that benefit under Article 23 of the Indo-Thai DTAA could only be… Read More

ITAT Kolkata held that non-resident Indian who has provided services as an employee outside India (i.e. in Morocco) is entitled to claim benefit of Article 15(1) of the India Morocco DTAA. T… Read More

In present facts of the case, it was held that the services rendered were in the nature of advisory services as per the terms of the agreement, therefore these services cannot be the part of… Read More

ITAT Delhi held that receipts from disaster recovery playout services and disaster recovery up-linking services are not in the nature of Fee for Technical Service (FTS) as envisaged under Ar… Read More

Read the analysis of SPI Global US vs ACIT (ITAT Delhi) case where sub-contracting charges taxability under India-USA DTAA was contested. Learn about the make available clause and the final… Read More

Welcome to a new Monday post with 3 random thoughts on all things guitar, music, and life, including thoughts on home, the brake / blast method, and more. Here we go…   #1 &nda… Read More

Here’s a little case study on how to learn anything on your guitar to a high standard… It’s a great example of the journey we all go on when learning a new skill or techni… Read More

ITAT Delhi held that the income from technical handling services received from ‘International Airlines Technical Pool (IATP) members is not taxable in India as it is covered under Arti… Read More

ITAT Delhi held that cost to cost reimbursement on account of secondment of employees cannot be treated as Fees for Technical Services (FTS) as defined under Article 12 of India USA-Double T… Read More

TDS section 195 Tax Deducted at Source (TDS) is a mechanism employed by the Indian government to collect taxes at the very source of income generation. It requires the payer to deduct a… Read More

Earlier in the week, I talked about how it’s been almost ten years since I quit my old job to become a full-time guitar tutor. And yesterday, I mentioned a big announcement coming up t… Read More

Today I’ve just released the new Dan Thorpe Acoustic Academy lessons. In a few hours (at midnight Pacific time), the cart will close, so this is the last chance to join for a while an… Read More

I had an interesting email the other day from Stu, who is a Dan Thorpe Acoustic Academy member. He was asking about which other courses he should purchase to go alongside his membership… Read More

Foreign Tax Credit Foreign Tax Credit (FTC) is a mechanism designed to prevent double income taxation arising in one country and is subject to tax in another. This system is crucial for… Read More

Welcome to a new Monday post with 3 random thoughts on all things guitar, music, and life, including thoughts on a practice warning, adapting to your schedule, and more. Here we go… … Read More

Today’s episode of the Acoustic Asylum podcast is a very special one. Inside, I’m sharing my backstory of how I got started teaching guitar full-time… …And why we a… Read More

I’m a big fan of the classical position. …Especially when using a strap to help secure the guitar. I call it ‘CWAS’ (Classical With A Strap). This way of sitting c… Read More

ITAT Delhi rules that receipts from reselling hardware and software packages by Avnet Asia Pte Ltd aren't considered 'Royalty' under India-Singapore DTAA. The post Reselling of Hardware and… Read More

ITAT Mumbai's ruling in Spark44 vs. ACIT case highlights failure to consider India UK DTAA provisions for tax deduction on FTS. Analysis and conclusion included. The post ITAT Mumbai Directs… Read More

Here are two more interesting emails I have got lately. I hope you find the emails and my thoughts useful… Today we are talking about left-handed people trying to play right-handed&he… Read More

Here’s a guitar lesson taken from the gym. Years ago, I first started training in the gym. It was terrible. I’d hop from one machine to another, do some free weights, jump on t… Read More

ITAT Bangalore held that payments received by assessee towards interconnectivity utility charges from Indian customers / end users cannot be considered as Royalty / FTS to be brought to tax… Read More

Taxation for Social Media Earnings The internet’s rise has revolutionised how individuals generate income, allowing them to monetize their content across various social media platf… Read More

In a few hours, I’ll be closing down enrolment for the Dan Thorpe Acoustic Academy. As a polite reminder, if you join before (midnight PST time), you will get the new No Chord Fingerst… Read More

NRI Investments in India Investing in India as a Non-Resident Indian (NRI) offers a world of possibilities, yet it comes with complexities. NRIs are presented with diverse investment opp… Read More

Held by Hon’ble High Court of Delhi In the matter of  Principal Commissioner of Income Tax Vs. M/s Polypex Corporation Limited (ITA 571/2019 dated 18.07.2023) The Asse… Read More

An in-depth analysis of the ITAT Chennai's decision on ITO vs Eshakti Com Pvt Ltd, focusing on the deletion of disallowance under section 40(a)(i) of the Income Tax Act. The post AO cannot t… Read More

ITAT Bangalore held that in case of non-resident, income arising in India by way of royalties or technical charges could be taxed in India but that could be only on the receipt basis under I… Read More

A detailed look at the recent ITAT Ahmedabad ruling in the case of Manoj Kaushikprasad Jingar Vs Assessing Officer. Explore how the tribunal addresses the issue of late filing of Form No.67… Read More

Here are two more interesting emails I have got lately. I hope you find the emails and my thoughts useful… Email #1 “This will sound stupid and I am. I am almost 2 months into… Read More

ITAT Bangalore held that payments received towards interconnectivity utility charges from Indian customers / end users cannot be considered as Royalty to be brought to tax in India under sec… Read More

ITAT Delhi held that as shares were acquired prior to 01.04.2017, gain derived from sale of such equity shares is exempt under Article 13(4) of India-Mauritius DTAA. The post Gain from sale… Read More

ITAT Delhi held that receipts from background screening provided by the assessee to its customers in India cannot be regarded as Royalty or Fees for Technical Services (FTS) under Article 13… Read More

An in-depth analysis of the Ramesh Kumar AE Vs ITO (ITAT Chennai) case. Discover why the ITAT Chennai ruled that salary earned in a foreign jurisdiction is not taxable in India. The post Tax… Read More

Double Taxation avoidance agreement is entered between two countries to avoid dual taxability of the same income in 2 countries. Section 90 of Income Tax Act, 1961, permits the central gover… Read More

Here are two more interesting emails I have got lately. I hope you find the emails and my thoughts useful… Today we are talking about how cool it is when you feel like a ‘real&r… Read More

Double Taxation Avoidance Agreement (DTAA) is entered between two countries to avoid double taxation, i.e., same income is being taxed in both countries, maintaining mutual economic relation… Read More

ITAT Delhi held that salary income not taxable in India both u/s. 9(1) as services are rendered outside India and also not taxable under Article 15(1) of India-Netherland DTAA as required co… Read More

Income Tax Return for NRIs Taxation forms the foundation of any country’s economy, and India is no exception. For India, a nation with a substantial overseas population, the taxati… Read More

ITAT Delhi held that consideration paid for testing the ability of candidates do not fall within the purview of royalty under Article 13 of India-UK DTAA. Hence, there is no obligation withh… Read More

ITAT Mumbai held that Broadcasting Reproduction Right is not covered under the definition of Royalty under the Income Tax Act as well as Article 12 of the India-USA DTAA. The post Broadcasti… Read More

ITAT Delhi held that as per India-USA DTAA provision of consultancy services cannot be treated as FIS merely because the service provider while providing consultancy services had used substa… Read More

ITAT Delhi held that income from subscription, professional and training services for use of software doesn’t fall within the definition of Fees for Technical Services (FTS) under Indi… Read More

Just want to give you a quick heads-up, today is the last chance to get the new Dan Thorpe Acoustic Academy lessons. If you like the blues, you will love these new lessons. In fact, if you… Read More

New Dan Thorpe Acoustic Academy member, Sean Richards, checks in with this comment: “I have got to admit that my ability to practice without pain has multiplied in time many times ove… Read More

The time has come for India and Taiwan to embark upon the journey of reimagining their economic relationship. Having historically maintained ‘unofficial’ ties, there has been a n… Read More

ITAT Delhi held that payments received by the assessee qualifies as Fees for Technical Services (FTS) under sub-clause (4) of Article 12 of Indo – Singapore DTAA and hence rightly brou… Read More

ITAT Delhi held that amount received towards service rendered by the assessee is in connection with installation/erection of plant and machinery involved in mining of natural resources fall… Read More

NRI Taxation in India We all recognize that taxes collected from citizens form the bedrock of India’s economy. However, the Indian Income Tax Act of 1961 prescribes a distinct taxa… Read More

In an increasingly interconnected world, the allure of investing in the United States stock market has captivated investors from around the globe. For Indians looking to diversify their inve… Read More

A Foreign Company connects with India through various commercial transactions such as having a project office/ Branch Office/ Liaison Office in India, Making Foreign Direct Investment in Ind… Read More

Held that the amounts received for the use of transponder of tele-communication service charges are not royalty under section 9(1)(vi) of the Income Tax Act and also under Article 12(8) of I… Read More

Learn why a Section 90(1) notification is crucial for a DTAA's enforcement, as per the Supreme Court's landmark judgment in AO vs. Nestle SA. Understand its impact and implications. The post… Read More

Introduction: When engaging in foreign remittances, it is vital to understand the specific documentation requirements for issuing Form 15CA/CB. These forms play a critical role in ensuring T… Read More

As the world continues to shrink due to globalization and the ease of international travel and communication, Non-Resident Indians (NRIs) find themselves in a unique position. They have root… Read More

ITAT Delhi held that services are rendered without transfer of technical knowledge, skill, know-how, etc. and accordingly the receipts doesn’t qualify as FIS (Fees for Included Service… Read More

Form 10F is required to be filed by non-residents for claiming benefit of Double Taxable Avoidance Agreement (DTAA) so that they can get income without deduction of TDS in India. Recently, N… Read More