🏦 CIT (IT) v. HSBC Bank (Mauritius) Ltd – Bombay High Court on Exemption of Interest Income under India–Mauritius DTAA (2024) 📘 Background The taxation of interest income under Section 9(1)(v) of the Income-tax Act, 1961, often leads to disputes in cross-border banking transactions, especially where Double Taxation Avoidance Agreements (DTAAs) provide preferential treatment to […]
![Devi Dayal v. Asst. CIT (IT) [2024]](https://cabulalo.com/wp-content/uploads/2025/12/Untitled-design-18.jpg)
🏢 Devi Dayal vs. ACIT (IT) – ITAT Delhi on Taxability of Salary Paid in India for Services Rendered Abroad under India–Austria DTAA (2024) 📌 Background A recurring question in international taxation concerns whether salary paid in India to a non-resident employee deputed abroad for work is taxable in India, especially when the services are […]
🌍 Sanjay Kumar vs. ACIT (IT) – ITAT Delhi on Taxability of Salary Earned Outside India by a Non-Resident under India–UAE and India–Ireland DTAAs (2024) 📌 Background The determination of taxability of salary income earned abroad by non-resident Indians (NRIs) continues to be a key issue in international taxation, especially for individuals working across multiple […]
⚓ Pralay Pradyotkanti Ghosh vs. ITO (IT) ITAT Ahmedabad on Taxability of Salary Earned in International Waters under India–Singapore DTAA (2024) 📌 Background The determination of whether salary earned by a non-resident Indian (NRI) for services rendered in international waters constitutes income accruing or arising in India under Section 9(1)(ii) of the Income-tax Act, 1961, […]
📺 Taj TV Ltd. vs. DCIT (IT) – ITAT Mumbai on Dependent Agent PE and Business Connection under India–Mauritius DTAA (2024) 📌 Background The issue of Dependent Agent Permanent Establishment (PE) under Article 5(4) of Double Taxation Avoidance Agreements (DTAAs) has been central to determining whether income earned by foreign media and broadcasting companies from […]
⚙️ Jiangdong Fittings Equipments Co. Ltd. vs. ACIT – ITAT Delhi on Offshore Supplies and Non-Taxability of Business Profits under India–China DTAA (2024) 📌 Background Taxation of offshore supply contracts has been a recurring issue in international taxation, particularly in cases where non-resident suppliers enter into composite contracts with Indian entities involving both supply of […]
🏦 BNP Paribas vs. ACIT – ITAT Mumbai on Taxability of Interest Paid by Indian Branch to Foreign Head Office under India–France DTAA (2024) 📌 Background Cross-border taxation of intra-entity transactions—especially between a foreign bank’s head office and its Indian branch—has long been a debated topic in international tax jurisprudence. The central question revolves around […]
🌐 Sabre GLBL Inc. vs. ACIT – ITAT Delhi on Business Connection and Permanent Establishment under India–USA DTAA (2024) 📌 Background In the digital era, multinational enterprises providing computerized reservation systems (CRS) for airlines and hotels often face scrutiny regarding taxability in India under Section 9(1)(i) of the Income-tax Act, 1961, and the corresponding provisions […]
⚙️ General Motors Company USA v. ACIT (IT) – Delhi ITAT on Residency of US LLC and Eligibility for DTAA Benefits under Indo–US Tax Treaty (2024) 📌 Background A key issue in cross-border taxation is whether a Limited Liability Company (LLC) incorporated in the United States, which is treated as a fiscally transparent entity under […]
⚙️ GE Hydro France v. Dy. CIT (IT) – Delhi ITAT on Offshore Supply, Absence of Permanent Establishment & Inapplicability of Section 44BBB under India–France DTAA (2024) 📌 Background In cross-border infrastructure and engineering projects, foreign contractors often face disputes regarding taxation of offshore supplies and the applicability of Section 44BBB of the Income-tax Act, […]