Tax relief u/s 90 - the argument that in the absence of an ...

Case Laws Income Tax

October 13, 2015

Tax relief u/s 90 - the argument that in the absence of an agreement between India and the State, the benefit of Section 90 is not available to the assessee is ex-facie illegal and requires to be set aside - HC

View Source

← Previous Next →

Tax relief u/s 90 - the argument that in the absence of an ...

Case Laws Income Tax

October 13, 2015

You may also like:

Section 90 of the Income Tax Act allows relief from double taxation by granting foreign tax credits (FTCs) on foreign income taxed in both India and the other country....

Disallowance of State taxes paid overseas - relief under section 90 - Pertinently, unlike section 91 read with Explanation–(iv), section 90 does not provide for...

The Income Tax Appellate Tribunal (ITAT) held that denial of tax relief u/s 90/90A solely due to procedural delay in filing Form-67 is unjustified. Filing of Form-67 is...

Foreign tax credit claimed under Article 24 of India- UK DTAA read with Section 90 - assessee who is a resident of India and has derived from salary which has suffered...

Relief u/s. 90 - Foreign Tax Credit (FTC) - In the instant case, the delay in filing of the FTC certificate in Form-67 was explained to be due to non receipt of the tax...

Income taxable in India - salary derived from Tanzania - resident but not ordinarily resident in India - eligibility of Relief u/s 90 - the salary is earned outside...

Income accrued in India - receipts of the assessee from sale of software - In view of Section 90(2) of the Income Tax Act, the assessee opts for Double Taxation...

Income accrued in India - Benefit of India-UK Tax Treaty - Whether the assessee has PE in India and the receipts are liable to be taxed as ‘Business Profits’? - if the...

Section 90 of the Income-tax Act, 1961 - Double Taxation Agreement - Agreement for Avoidance of Double Taxation and Prevention of fiscal evasion with foreign countries -...

Income accrued in India - Period of stay in India - This claim of the assessee has not been rebutted or denied by any of the lower authorities. Both the lower...

Income accrued in India - permanent establishment (PE) - Withholding of tax in India - vessel engaged in seismic survey at high sea - The sum paid by the applicant to...

Taxability of receipts as 'fees for included services' under the India-USA Double Taxation Avoidance Agreement (DTAA). The key points are: The Assessing Officer (AO)...

Claim of foreign tax credit (FTC) u/s 90 or u/s 91 - Applicability or Rule 128 with retrospective effect - In view of Singapore Taxation Laws the income in question is...

Foreign tax credits u/s 90/90A - Rule 128 is a procedural provision and not a mandatory provision - Rule 128 nowhere provides that if the said Form 67 is not filed...

Income accrued in India - income in respect of “off-shore supply” of equipment - DTAA between India and Austria - The part of the operations of supply agreement have...

Quick Updates: