Tag Archives: International Taxation

Penalty Under Section 270A Is Unsustainable Once Underlying Assessment Order and FTS Adjustment Are Quashed

By | August 11, 2026

Penalty Under Section 270A Is Unsustainable Once Underlying Assessment Order and FTS Adjustment Are Quashed Penalty Under Section 270A Is Unsustainable Once Underlying Assessment Order and FTS Adjustment Are Quashed Issue Whether a penalty under Section 270A for misreporting of income can be sustained when the underlying assessment order and Fee for Technical Services (FTS)… Read More »

Miscellaneous Application for Rectification Under Section 254 Dismissed as No Error Found in Tribunal Stay Order

By | August 6, 2026

Miscellaneous Application for Rectification Under Section 254 Dismissed as No Error Found in Tribunal Stay Order Issue Whether a Miscellaneous Application under Section 254(2) for rectification can be entertained to direct a refund or impose costs when the assessee points out no mistake apparent from the record in the Tribunal’s original stay order. Facts The… Read More »

In the absence of an FTS clause, Thai company’s technical receipts are non-taxable business profits without an Indian PE.

By | June 20, 2026

In the absence of an FTS clause, Thai company’s technical receipts are non-taxable business profits without an Indian PE. Issue Whether, in the absence of a specific Fees for Technical Services (FTS) clause in the India-Thailand DTAA, payments received by a Thai resident company from Indian group entities for management and technical services can be… Read More »

Direct Tax Laws & International Taxation CA FINAL | A.Y. 2022-23 | BOOK

By | September 19, 2022

Direct Tax Laws & International Taxation (DT) | A.Y. 2022-23 | CA FINAL TEXTBOOK Direct Tax Laws & International Taxation CA FINAL  TEXTBOOK  provides practical application of Direct Tax Laws & International Tax in a holistic approach while testing the analytical skills of the reader. The crux of this book is to strike a perfect… Read More »

Free Book on Aspects of International Taxation — A study (Revised 2016)

By | November 5, 2016

Free Book on Aspects of International Taxation — A study (Revised 2016) (Case laws are updated till July, 2016) Download Book on Aspects of International Taxation — A study International Taxation due to its dynamic and ever changing nature has always been a complex subject not only to study but to practice. Due to increase in… Read More »

Australian Taxation Office updated guidance on general anti-avoidance rules

By | September 24, 2016

Australian Taxation Office updated guidance on the application of the general anti-avoidance rules. After much anticipation, the Australian Taxation Office (ATO) has released a revised practice statement on the application of the general anti-avoidance rules (Law Administration Practice Statement (PSLA) 2005/24). Click to View :   (PSLA) 2005/24).   application of the general anti-avoidance rules The… Read More »