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Search Results for "double tax avoidance agreement"

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High Court

Bombay High Court Allows Revenue's Appeal in Income Tax Case Involving Non-Resident Company - Denial of Treaty Benefits and Business Connection Upheld. The court held that the Tax Residency Certificate is not conclusive and the Assessing Officer can examine the substance of the arrangement to determine treaty eligibility.

16 Jun 2023

The case involves an appeal by the Commissioner of Income Tax (International Taxation) against the order of the Income Tax Appellate Tribunal (ITAT) i...

High Court

Madras High Court Dismisses Revenue's Appeal in Penalty Case for Wrongful DTAA Claim — No Concealment Found. Assessee's Bonafide Belief That India-China DTAA Applied to Hong Kong Based on Official Document Precludes Penalty Under Section 271(1)(c) of Income Tax Act, 1961.

5 Feb 2026

The revenue appealed against the common order of the Income Tax Appellate Tribunal (ITAT) which set aside the levy of penalty under Section 271(1)(c) ...

High Court

Bombay High Court Allows Assessee's Reference in Income Tax Case - Payment to Japanese Company for Technical Advisory Services Held Not Taxable Under DTAA. The court ruled that fees for technical services are 'industrial or commercial profits' under Article III of the India-Japan DTAA and not taxable in India in the absence of a permanent establishment.

14 Sep 2012

The case involves an Income Tax Reference under Section 256(1) of the Income Tax Act, 1961, arising from RA Nos.1052 and 1053/Bom/1991, which stem fro...

Supreme Court

Supreme Court Disposes of Appeals by Authority for Advance Rulings Against High Court Judgment Quashing AAR's Rejection of Treaty Benefits. Questions Raised on Taxation of Capital Gains Under India-Mauritius DTAA and Scope of Section 245R(2) Proviso (iii) of Income Tax Act, 1961.

1 Jan 1970

The disputes arose from applications for advance ruling filed by three Mauritius-incorporated companies—Tiger Global International II Holdings, Tige...

High Court

Bombay High Court Reviews Advance Ruling Holding Business Support Services Payments Taxable as Fees for Technical Services Under India-UK DTAA. Court Examines Whether 'Make Available' Requirement in Article 13.4(c) is Satisfied and Whether Withholding Tax Obligation Under Section 195 of Income Tax Act, 1961 Arises.

1 Mar 2024

The writ petition before the Bombay High Court arose from an order of the Authority for Advance Rulings (AAR) dated 17 January 2012, which held that p...

High Court

Bombay High Court Allows Writ Petition Challenging Rejection of Nil Tax Withholding Certificate Under Section 197 of Income Tax Act, 1961 — Holds That Payments for International Delivery Services Are Not Royalty or Fees for Technical Services Under DTAA. The court directed issuance of nil withholding certificate as the payments are business profits not taxable in India under Article 7 of the India-USA DTAA.

30 Sep 2013

The petitioner, UPS Worldwide Forwarding Inc., a US company, challenged an order dated 21 March 2013 passed by the Director of Income Tax (Internation...

High Court

Bombay High Court Allows Revenue's Appeal in FII Capital Gains Tax Case — Remands to ITAT for Fresh Consideration of Article 24 DTAA Compliance. Interpretation of Article 24 of India-Singapore DTAA requires examination of whether capital gains were subject to tax in Singapore on receipt basis.

21 Jun 2023

The case involves an appeal by the Commissioner of Income Tax (IT) - 2 against an order of the Income Tax Appellate Tribunal (ITAT) dated 24 March 201...

High Court

Bombay High Court Allows Writ Petition Challenging Rejection of Application Under Section 197 of Income Tax Act for Lower Tax Deduction on Dividend Income. The court held that a Tax Residency Certificate (TRC) is sufficient evidence of residence for claiming treaty benefits under the India-Mauritius DTAA, and the Assessing Officer must consider the DTAA provisions.

26 Apr 2019

The petitioner, Indostar Capital, a Mauritius-based company incorporated in October 2010, held a Category 1 Global Business Licence and a Tax Residenc...

High Court

Bombay High Court Dismisses Petition Challenging Rejection of TDS Refund Under Section 264 of Income Tax Act, 1961. Assessee Failed to Establish That Payments to Foreign Collaborator Were Not Royalty Under Section 9(1)(vi) Read with DTAA.

28 Oct 2005

The petitioners, M/s BASF (India) Limited and Mr. P.A. Ramasamy, filed a writ petition challenging the order dated 28th February 2001 passed by the Co...

High Court

High Court of Karnataka Dismisses Revenue's Appeal in TDS Dispute — Payment to Non-Resident for Software Not Royalty Under Section 9(1)(vi) of Income Tax Act, 1961. Payment for shrink-wrapped software held to be for copyright article, not transfer of copyright rights, thus not taxable as royalty.

9 Mar 2015

The case involves two appeals filed by the Revenue (Commissioner of Income Tax and Deputy Commissioner of Income Tax (TDS)) against the common order o...

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