Clarification on whether TDS is required to be deducted under section 195 of the Income Tax Act, 1961
Clarification on whether TDS is required to be deducted under section 195 of the Income Tax Act, 1961
Is the decision on FTC correct? – Critical analysis In the case of Canon India, the company was …
A Limited Liability Company (LLC) was incorporated in the US and was wholly owned by a US corporation, …
Dual resident companies – Can TRC be rejected? In a recent case before India’s Tax Tribunal involving eBay …
Article 13 or Article 10? What if both articles Apply? I recently had an engaging conversation with a …
Interpreting the words “incidental to” Facts: The disputed years are 2014 and 2015.
I don’t think so! The key difference lies in the technical explanations of the India-US DTA and Ireland-US …
Liable to tax” – Non-discrimination clause – Irish group relief – USA-Ireland DTA Facts: Two Irish subsidiaries were …
Article 15 of France-UK DTA – Dependent personal services – published on 11 April 2025 Facts: The years …
Can foreign PE be considered as employer under the treaty? Facts: A company incorporated in Germany maintained foreign …
