Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
The India-Japan Memorandum of Understanding for assistance in collection of taxes under Article 26A is notified for effect in India. The memorandum, signed at Tokyo and New Delhi in 2025, applies to requests for collection of taxes made after the later date of signature by the two competent authorities, namely 8 July 2025. The notification gives effect in the Union of India to all provisions of the memorandum as set out in the annexure, thereby operationalising the agreed framework for tax-collection assistance between the two countries.
The India-Japan Memorandum of Understanding for assistance in collection of taxes under Article 26A is notified for effect in India. The memorandum, signed at Tokyo and New Delhi in 2025, applies to requests for collection of taxes made after the later date of signature by the two competent authorities, namely 8 July 2025. The notification gives effect in the Union of India to all provisions of the memorandum as set out in the annexure, thereby operationalising the agreed framework for tax-collection assistance between the two countries.
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