Permanent Establishment Doctrine Explained Through Hyatt International Case
In this video, Adv Tarun Jain, author of Goods and Services Tax: Constitutional Law and Policy explains the Supreme Court’s landmark ruling
DTAA
Cyprus Arbitration Day 2026 Kicks Off with Discussions on India-Cyprus relations, Investment Treaties and AI in arbitration
On the eve of Cyprus Arbitration Day 2026, experts gathered to kick-start the event with an evening full of insightful panel discussions on international arbitration landscape, India as an arbitration seat, BITs and DTAAs, and much more.
Delhi High Court: ‘Subscription Fee’ income not classified as ‘royalties’ or ‘included services’ under DTAA and IT Act
Delhi High Court elucidated the treatment of subscription fees vis-à-vis royalties and technical services under both the Double Taxation Avoidance Agreement (DTAA) and the Income Tax Act and clarified the distinction between income from subscription fees and payments for intellectual property rights or technical consultancy services.
Notification under Section 90(1) of Income Tax Act mandatory for giving effect to a DTAA or protocol: Supreme Court
“Upon India entering into a treaty or protocol does not result in its automatic enforceability in courts and tribunals; the provisions of such treaties and protocols do not therefore, confer rights upon parties, till such time, as appropriate notifications are issued, in terms of Section 90(1).”
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
Amounts paid by Indian companies to non-resident manufacturers/suppliers for resale/use of the computer software not royalty, hence, not taxable in India: Supreme Court [Read detailed report]
DTAA provisions must be treated as law and followed by Indian courts, notwithstanding what may be contained in the Income Tax Act to the contrary, unless more beneficial to the assessee.