The assessee was a foreign company incorporated in Netherlands having its principal branch office in India. In course of its banking activities, the assessees said branch in India remitted substantial funds to its head office as payment of interest. The two question raised before Kolkata High Court was whether such interest payment was to be [...]
Interest Paid By Branch to Principal Non Resident Company based at Netherland Not Taxable !
Is Deduction u/s 80HHE Available to Non Residents ?

The assessee was a an Individual having tax residency of USA.The assessee had a Permanent Establishment in India (PE) in form of proprietary concern for export of software.He claimed deduction u/s 80HHE in respect of export of softwares. However, both the Assessing Officer as well as the Commissioner (Appeals) were of the opinion that deduction...
Australia DTAA: Whether Interest on Refund Taxable under Article XI ?
The assessee was a non-resident company having a permanent establishment in India. The assessee earned various income mainly from the contract with ONGC, ‘C’ Ltd. and ‘N’ Ltd. One of the income declared by the assessee-company was interest on income-tax refund which it claimed taxable @ 15 % on gross basis in view of the...
Why Mauritus Registerd FII & Companies Don’t Pay Tax on Capital gains !
Income Tax Act 1995 governs the taxation of resident Mauritian companies. Under the law prevailing in Mauritius , taxable income includes rents, dividends, royalties and interest; however, dividends paid by 'tax incentive' companies, companies listed on the stock exchange, and companies which pay the full tax rate are exempt from tax in the hands of the receiving shareholder, whether resident or not.Most importantly ,there is no tax on capital gains arising on investments in shares
Should Payment For Booking Exhibition Space Abroad Suffer TDS?
We are running an educational institution and accordingly we have booked an exhibition floor space in uae as a part to promote our institution . now the question is that the company which is organizing is a foreign company say ( international exhibition llc). it is not having any permanent establishment in iIdia . do



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