Judgement

The ITAT Mumbai held that executive search fee received by a Netherlands company cannot be taxed as FTS

ITAT Rules Executive Search Fee Not Taxable as FTS Under India-Netherlands DTAA

The ITAT remanded the software/SaaS FTS issue for fresh assessment and ruled that DTAA tax rates cannot be increased by surcharges/cess.

ITAT Sends Software and SaaS FTS Dispute Back for Fresh Review, Rules DTAA Tax Capping Includes Surcharge and Cess

Notifications

New protocol amends India-Sri Lanka DTAA to curb treaty shopping through a Principal Purpose Test.

India Notifies India-Sri Lanka DTAA Protocol Introducing Principal Purpose Test

The ITAT Delhi held that a delayed filing of Form 67 is only a procedural lapse and cannot be the sole ground for denying Foreign Tax Credit under the DTAA.

Delay in Filing Form 67 Cannot Deny Foreign Tax Credit Under DTAA, Holds ITAT 

The ITAT held that DDDT on dividends paid to Swiss shareholders cannot exceed the 10% rate prescribed under the India–Switzerland DTAA and directed the refund of the excess tax paid.

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ITAT Rules Executive Search Fee Not Taxable as FTS Under India-Netherlands DTAA

ITAT Sends Software and SaaS FTS Dispute Back for Fresh Review, Rules DTAA Tax Capping Includes Surcharge and Cess

India Notifies India-Sri Lanka DTAA Protocol Introducing Principal Purpose Test

Delay in Filing Form 67 Cannot Deny Foreign Tax Credit Under DTAA, Holds ITAT

ITAT Restricts DDT to 10% Under India-Switzerland DTAA; Orders Excess Tax Refund

ITAT Deletes FTS Addition on Business Support Services Under India-Singapore DTAA