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DTAA - Deploying specialized software, technical resources, or copyrighted items as medium to deliver services does not amount to granting right to use copyright or intellectual property per India-USA DTAA; consideration payable therefor is not Royalty: ITAT (See Breaking News) I-T - Assessee is entitled to concessional rate u/s 115BAA despite delayed filing of Form 10-IC, when option had already been exercised in return of income: ITAT (See Breaking News) INTL - Once Revenue accepts that no income is taxable in India for relevant AY, the corresponding TDS deducted at source cannot be withheld & assessee is entitled to claim credit per Rule 37BA of I-T Rules: ITAT (See Breaking News) INTL - Digital transmission & uploading of orders on ITBA portal is valid receipt by AO, effectively starting limitation clock from that date rather than from any subsequent physical handling or note-sheet entry: ITAT (See Breaking News) DTAA - Payment for managerial, technical or consultancy services constitutes Fees for Technical Services only where such services are provided by resident of one contracting State in other contracting State: ITAT (See Breaking News) I-T - Final assessment order passed u/s 143(3), 144C(13) and 144B can be quashed as time-barred if it is passed beyond outer limitation prescribed u/s 153 r/w/s 144C: ITAT (See Breaking News) I-T - Subsidiary with own manufacturing unit, independent customer base can't not be treated as economically dependent on its foreign parent, and does not constitute a Dependent Agency PE: ITAT (See Breaking News) TP - Fully & compulsorily convertible debentures retain their character as debt until actually converted into shares & regulatory frameworks or accounting standards operating in different fields cannot be imported to alter this position for transfer-pricing purposes: ITAT (See Breaking News) TP - Revenue must first establish existence of international transaction regarding AMP expenses de hors Bright Line Test, which has no statutory mandate: ITAT (See Breaking News) I-T - Requirement of furnishing Form 67 is directory and procedural & cannot override substantive entitlement to credit for foreign taxes paid u/s 90 or 90A: ITAT (See Breaking News) TP - For cross-border transactions involving foreign currency receivables, the appropriate interest rate to adopt is LIBOR rate rather than domestic rates: ITAT (See Breaking News)
 
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Taxindiainternational.com (“TII”), established on April 23, 2010, is a dedicated portal on international taxation. TII was launched in response to the changing landscape of taxation in India. It happens to be the FIRST comprehensive and exhaustive online resource for the taxpayers and also tax authorities looking for well-arranged resource on Transfer Pricing, Double Taxation Tax Treaties, FDI, FEMA, PMLA, BIPA, NRI and Visa guidelines for various categories of expatriates employed in India by MNEs. 

TII is a sister portal of India’s most prestigious and popular taxation and trade portal Taxindiaonline.com (TIOL). In about to be nine years, TII has carved a niche for its quality, speed and authenticity among domestic as well as international users. It has earned the respect and confidence of many global experts of international taxation. It is a highly reliable resource for the various fora of the Indian judiciary. Its citations are frequently used by the courts in their decisions. Its well-researched articles are regularly referred to by the policy makers in India. Its recommendations are generally respected by the Ministry of Finance in India.

TII has a huge subscriber-base cutting across users community ranging from Foreign Taxation Division in the CBDT, Directorate of Transfer Pricing & International Taxation to advocates, law firms, MNEs, domestic companies and research organisations. It has an enviable team of in-house experts and Consulting Editors who keep an eye on the global trend and keep sensitising the policy makers on the future trends of transforming fiscal world.

Consulting Editor


Mr. D.P. Sengupta: Mr Sengupta, a former member of the IRS, retired as Chief Commissioner of Income Tax after more than 33 years of distinguished service. Before that he had a highly satisfying stint as Joint Secretary in the Tax Policy and Legislation division of the Central Board of Direct Taxes.He also served as Joint Secretary in the Foreign Taxation Division of the Ministry of Finance. He was the Competent Authority for India and represented India in the WP1 of the OECD. He is a well known international taxation expert and spoke at various international tax conferences.

CEO & Managing Editor

Shailendra Kumar, founder and CEO of TIOL started his career with The Indian Express Newspaper in 1990 and then moved to The Economic Times where he worked for more than five years before taking the entrepreneurial route to launch TIOL, an idea based on a business need which he realized as a financial journalist. His vision was to create a knowledge-driven company; which eased the burden on corporations and which acted as a media watchdog for Indian tax and trade policies. He spearheads the business in all of its facets, including regular interactions with various policy makers and administrators, and managing the editorial and news gathering team at TII. He is the recipient of the 2001 Outstanding Media Professional Award presented by the India International Professionals Forum.

 
 
 
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