Loading...

⚠ ✕
❮ Top
☎ Help
☰
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search ✕
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
  6. Text Search
  7. The system will try to fetch results that contains ALL your words.
  8. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
  9. Text Search
╳
Add to...
You have not created any category. Kindly create one to bookmark this item!
✕
Create New Category
Hide
Title :
Description :
❮❮ Hide
❮ Default View
Expand ❯❯
Close ✕
🔎 Filters / Advanced Search ❯
TEXT

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In
Main Text + AI Text ❯
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws---- ❯
  • ---- All Laws----
  • Income Tax
  • Direct Taxes
  • Benami Property
  • Central GST Laws
  • SGST - State GST Laws
  • Customs
  • FTP - Foreign Trade Policy
  • SEZ - Special Economic Zone
  • FEMA - Foreign Exchange Management
  • Companies Law
  • SEBI - Securities & Exchange Board of India
  • IBC - Insolvency and Bankruptcy
  • Law of Competition
  • PMLA - Money-Laundering
  • Indian Laws
  • Bill / Finance Bills
  • Wealth Tax
  • Service Tax
  • Central Excise
  • VAT / Sales Tax
Month:
---- All Months ---- ❯
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ---- ❯
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
    Research institution approval enables donation-linked tax treatment subject to SIRO status, annual reporting, donor certification, and rule compliance...
    Scientific research institution approval enables donation-related tax treatment subject to ongoing SIRO status and annual reporting compliance.
    Research institution approval grants tax-law recognition, subject to continuing SIRO status and annual donor-reporting compliance.
    Raw sugar tariff-rate quota surrender deadline extended, with existing CIF-value payment condition and allocation terms unchanged.
    Investor awareness messaging becomes mandatory on broker websites and trading apps, alongside risk disclosures under phased implementation.
    Control of appellate income-tax commissioners now rests with jurisdictional Principal Chief Commissioners or Chief Commissioners.
    Minimum import price conditions for ATS-8 imports are extended, preserving existing CIF valuation requirements until late November.
    RELIEF Component II eligibility timelines extend for delivery and transshipment shipments, supporting exporters facing continuing logistics disruption...
    Scientific research approval requires continuing SIRO status, annual donation reporting, and donor certification for tax compliance purposes.
    Scientific research approval requires continuing SIRO status, annual donation reporting, and donor certificates throughout its effective tax years.
    Scientific research approval requires continuing SIRO status, annual donation reporting, and donor certification for tax-recognised contributions.
    Debenture trustee oversight: consolidated rules mandate independent security diligence, continuous covenant monitoring, default action, and investor g...
    Customs-controlled cargo movement now includes GDL, subject to EXIM prioritisation, segregation, verification, reconciliation and enforcement safeguar...
    Prior communication of CGST arrest authorisation is required; summonses cannot replace a distinct pre-arrest notice.
    GST search seizure powers exclude cash and securities absent a statutory nexus, requiring return or refund of unlawfully seized funds.
    Inverted duty refunds remain available where higher-taxed packing materials create accumulated ITC, despite restrictive administrative circulars.
    Misdescription of goods in transit records supports section 129 tax and penalty; post-interception documents cannot cure the breach.
    Pre-movement e-way bill compliance makes post-interception documents ineffective, supporting detention and penalty for undocumented goods in transit.
    E-invoice procedural lapse alone cannot sustain detention penalty where transport records establish a genuine taxable supply without tax evasion.
    Tariff classification of oversized kitchen exhaust hoods places integral-fan units in the residual entry rather than fans.
❮
❯
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Highlights
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries

Highlights

Back

All Highlights

Showing Results for :
Reset Filters
No Records Found

Highlights

Back

All Highlights

The assessee earned income from professional services rendered...

ITAT Rules Income from Overseas Professional Services Taxable in India; Allows Deduction for Japanese Withholding Taxes.

Contents
Summary
Note

Note

-

Bookmark

Print

Print

Income Tax November 22, 2024 Case Laws AT
The assessee earned income from professional services rendered in foreign countries like Japan, Nepal, and Singapore. The Income Tax Appellate Tribunal (ITAT) examined the provisions of Article 12 and Article 14 of the India-Japan Double Taxation Avoidance Agreement (DTAA) pertaining to Assessment Year 2017-18. It held that Article 12 of the DTAA provides that income from professional services or other independent activities would be taxable in the resident country, i.e., India. However, clause 4 of Article 12 excludes payments made to individuals for carrying out independent professional services referred to in Article 14 from the definition of 'fees for technical services.' The ITAT concluded that the Japanese tax authorities' decision to withhold taxes from payments made to the assessee by its Japanese clients cannot be considered unreasonable or incorrect. Consequently, the ITAT allowed the assessee's claim for deduction, deciding against the revenue authorities.

Topics

Acts Income Tax