Double Taxation Avoidance Agreement with Article 5

Supreme Court Clarifies “Preparatory or Auxiliary” Activities under DTAA: Union of India vs. U.A.E. Exchange Centre (24 April 2020)

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Supreme Court Clarifies “Preparatory or Auxiliary” Activities under DTAA: Union of India vs. U.A.E. Exchange Centre (2020) LEGAL ISSUE: Interpretation of “preparatory or auxiliary” activities under the Double Taxation Avoidance Agreement (DTAA). CASE TYPE: Income Tax Law Case Name: Union of India & Anr. vs. U.A.E. Exchange Centre Judgment Date: 24 April 2020 Introduction Date […]

Supreme Court Clarifies “Preparatory or Auxiliary” Activities under DTAA: Union of India vs. U.A.E. Exchange Centre (24 April 2020) Read Post »

Supreme Court clarifies Permanent Establishment (PE) norms in India-US DTAA: Assistant Director of Income Tax vs. E-Funds IT Solution Inc. (24 October 2017)

/ Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement with Article 27, Double Taxation Avoidance Agreement with Article 5, Double Taxation Avoidance Agreement with Article 7, Income Tax Act, 1961, Income Tax Act, 1961 with Section 90, Income Tax Rules, 1962 with Rule 44H, Judges, R.F. Nariman, Sanjay Kishan Kaul

LEGAL ISSUE: Whether a foreign company has a Permanent Establishment (PE) in India, making it liable for taxation in India under the India-US Double Taxation Avoidance Agreement (DTAA). CASE TYPE: International Taxation Case Name: Assistant Director of Income Tax-I, New Delhi vs. M/s E-Funds IT Solution Inc. Judgment Date: 24 October 2017 Date of the

Supreme Court clarifies Permanent Establishment (PE) norms in India-US DTAA: Assistant Director of Income Tax vs. E-Funds IT Solution Inc. (24 October 2017) Read Post »

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