Double Taxation Archives

Can Indian revenue authorities go after tax residency certificate issued by other tax jurisdiction and issue a re-assessment notice u/s 147 Income Tax Act? Delhi High Court rules

A clarificatory press release dated 1-03-2013 issued by the Finance Ministry pursuant to the 2013 amendment makes it clear that a Tax Residency Certificate is to be accepted and tax authorities cannot go behind it. Further, based on repeated assurances to foreign investors by way of CBDT Circulars as well as press releases and legislative amendments and decisions of the Courts, the revenue cannot go behind TRC.

Case Briefs Tribunals/Commissions/Regulatory Bodies

ITAT | Whether DTAA protection in respect of taxation of dividend in source jurisdiction, can be extended to ‘dividend distribution tax’ under S. 115-O, Income Tax Act, in the hands of a domestic company? Matter referred to larger Bench

Income Tax Appellate Tribunal (ITAT): A two-Member Bench of Pramod Kumar, Vice President and Amarjit Singh, Judicial Member, referred a seminal question

Cabinet Decisions Legislation Updates

Cabinet approves — Protocol amending Agreement between India & Sri Lanka for avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income

The Union Cabinet has approved the Signing and Ratification of the Protocol amending the Agreement between India and Sri Lanka for the