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The Ahmedabad Tribunal ruled that for determining the quantum of income which is to be treated as doubly taxed for the purpose of computing admissible tax credit, taking gross receipts as a basis is not a right approach.

The Supreme Court's decision in Authority for Advance Rulings v. Tiger Global International Holdings marks one of the most consequential moments in India's international tax jurisprudence since Vodafone.

In a recent Ruling, Authority for Advance Ruling (AAR) denied DTAA benefit in respect of indirect transfer of shares.

In eBay Singapore Services Private Limited v. DCIT, [TS-1343-ITAT-2025(Mum)], the Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) ruled that capital gains arising to a Singapore tax resident...

Recently, the Ahmedabad Bench of the Income Tax Appellate Tribunal ("Tribunal") ruled that mere non-furnishing of a Tax Residency Certificate ("TRC") cannot disentitle a taxpayer from claiming tax treaty benefits.

In a recent ruling, the Income Tax Appellate Tribunal, Delhi recognized and upheld the importance of the Tax Residency Certificate and held that a Mauritius-based Collective Investment Vehicle registered as a Foreign Portfolio Investor …

Watson Pharma Pvt Ltd 1- The taxpayer carried out Research and Development (R&D) activities in India for supporting the manufacturing functions of the Associated Enterprise (AE) outside India.

In a first ruling on the issue, the Income Tax Appellate Tribunal, Mumbai (Tribunal) in its recent judgment in the case of Asia Today Limited (Taxpayer) [ITA No. 4628/2006, ITA No.4629/2006...

The capital gains exemption under the Treaty was made coterminous with that under the India-Mauritius tax treaty.

The taxation of dividends underwent a change when in Finance Act 2020, dividends were made taxable in the hands of shareholders. Prior to this, since 1997, the dividend-paying...

The Delhi High Court (HC) in Tiger Global III Holdings v Authority for Advance Rulings, 2024 SCC OnLine Del 5987 overturned the decision of the Authority for Advance Ruling (AAR)...

The Indian and Mauritian Governments have recently signed a protocol dated 7 March 2024 (Protocol) to amend the India-Mauritius tax treaty (Tax Treaty).

Electrical material Center Co. Limited ("Taxpayer"), a company based in Saudi Arabia sent four service engineers in India to provide services to an Indian entity.

Dual Residency gets attracted when an expat in the year of move qualifies as a resident of the host country (i.e., the country in which he is deputed) as well as home country (i.e., the country of his residence).

India's Supreme Court ruling in Tiger Global sent shockwaves through foreign investors who structured their investments through Mauritius and similar treaty jurisdictions. Following diplomatic intervention at the highest levels, the Indian government introduced targeted amendments to its tax rules—but do these changes fully restore investor confidence, or do critical uncertainties remain?

On January 24, 2017, the Central Board for Direct Taxes issued a circular enumerating the Guidelines for Determining the Place of Effective Management (hereinafter referred to as "POEM Guidelines") of a company.

Global Capability Centres in India have evolved from basic support operations into strategic hubs handling high-value functions like R&D, analytics, and procurement. As these centres scale and take on more complex responsibilities, multinational enterprises face heightened tax risks around permanent establishment classification and transfer pricing compliance that require careful structural review and documentation.