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Delhi ITAT Clarifies on Taxability of Digital Services Under the India-Singapore DTAA
Delhi ITAT rules that digital service receipts under the India-Singapore DTAA are not ‘royalty’ or ‘FTS’, offering clarity on taxability.
Dec 31, 20245 min read
India-US DTAA: Delhi High Court on ‘Preparatory’ and ‘Auxiliary’ Activities Under Article 5
Delhi HC clarifies the scope of ‘preparatory’ and ‘auxiliary’ activities under the India-US DTAA, focusing on Permanent Establishments.
Dec 31, 20245 min read
Permanent Establishment or Misconception? ITAT Clarifies the 120-Day Rule
Does the 120-day rule always create a Permanent Establishment? ITAT clarifies the criteria for taxation under the India-USA DTAA.
Dec 30, 20244 min read
ITAT Delhi Rules on Non-Resident Taxation: Source-Based Income from Indian Entities Liable to Tax Despite DTAA Protection
The ITAT Delhi clarifies that Section 5(2) prevails over Section 9(2) for non-resident taxation when the income source is in India.
Dec 27, 20242 min read
Delhi High Court Upholds ITAT’s Ruling in the Absence of ‘Finding or Direction’ Under Section 150 of the Income-Tax Act, 1961
Delhi HC upholds ITAT's ruling that reassessment under s. 150 of the Income-Tax Act is invalid without a specific 'finding or direction.'
Dec 26, 20244 min read
Telangana High Court: Assessee's Inability to Disprove Sworn Statement Results in Tax Addition
Telangana HC rules that sworn statements under Section 132(4) hold evidentiary value unless effectively rebutted by the assessee.
Dec 24, 20242 min read
Finality in Tax Settlement: Delhi High Court Invalidates Unauthorized Reassessment Under the DTVSV Act
Delhi High Court rules that tax settlements under the DTVSV Act are final and prohibit unauthorised reopening of concluded disputes.
Dec 23, 20244 min read
The ITAT Bangalore clarifies Permanent Establishment and Fees for Technical Services under India-USA DTAA
SanDisk India's role in PE creation and reimbursements for seconded employees under India-USA DTAA analysed by ITAT Bangalore in key ruling.
Dec 23, 20244 min read
Delhi High Court Quashes Reassessment: Upholds Statutory Time Limits in Tax Cases
The Delhi HC quashes reassessment notices, reinforcing statutory time limits under the Income-tax Act and clarifying procedural safeguards.
Dec 12, 20243 min read