Double Taxation Avoidance Agreement with Article 7 Archives

Tax Deduction at Source (TDS) for Foreign Companies: Supreme Court Addresses Permanent Establishment in National Petroleum Construction Company vs. Deputy Commissioner of Income Tax (2022)

Supreme Court on TDS for Foreign Companies: National Petroleum Construction Company vs. Deputy Commissioner of Income Tax (2022) LEGAL ISSUE: Whether a foreign company is liable to pay tax on income from work done outside India, and the scope of tax deduction at source (TDS) for such companies. CASE TYPE: Income Tax Law Case Name: […]

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)

October 24, 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 »