Articles by CA Rohit Gupta

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International Tax - Case Law Analysis-2015: Series 1

  CA Rohit Gupta    23 March 2015 at 10:37

International Tax Update: IndiaForeign Remittance: TDS u/s 195: Case Law Analysis 2015: Series 1Some of the important case laws published during 2015 pertaining to TDS u/s 195 and/or taxability of foreign companies/non-resident entities in respect of



Interest income from India - Foreign Remittance - Taxation

  CA Rohit Gupta    16 March 2015 at 16:41

International Tax UpdateInterest Income from India- Foreign Remittance- TDS u/s 195 A. Taxation as per Domestic Law:A.1. Definition of Interest2(28A) "interest" means interest payable in any manner in respect of any moneys borrowed or debt



Place of effective management: Critical analysis

  CA Rohit Gupta    07 March 2015 at 18:28

PLACE Of EFFECTIVE MANAGEMENT : Corporate Tax Residence in India: Analysis and Safeguards The India Budget,2015 has proposed the amendment of Section 6 of the Income Tax Act which alters the conditions under which a company is resident in India by in



International Tax Update: Budget 2015

  CA Rohit Gupta    01 March 2015 at 17:58

Budget 2015 introduced in India on 28.02.2015 has made significant changes as far as international taxation are concerned. Major ones include:- Reduction in rate of tax on non-residents for royalties/fees for tec



TDS u/s 195: Reimbursement of Expenses

  CA Rohit Gupta    27 February 2015 at 10:40

Taxability of Reimbursement of expenses has always been a contentious issue. In most of the cases, assessee get away with non-taxability of reimbursement of expenses on the plea of no profit element. However, in some cases, even without profit elemen



TDS U/S 195- Reimbursement of salary of seconded employees

  CA Rohit Gupta    26 February 2015 at 10:39

Secondment of employees by foreign parent company to Indian subsidiary is a regular feature considering the requirements to meet their global standards of quality and to ensure proper functioning and assistance to Indian Subsidary Companies. However,



TDS u/s 195- Interesting Cases

  CA Rohit Gupta    07 February 2015 at 11:17

Peculiar Cases where Courts held Assessee Liable for Deduction of TDS u/s 195Withholding taxes u/s 195 in respect of transactions with Non-Residents has always been a bone of contention between Assessee and tax authorities. Though liability for deduc



Service tax on representation services by CA

  CA Rohit Gupta    16 May 2011 at 12:29

Finance Act, 2011 made the services rendered by legal firms taxable. And with this also rescinded the notification no. 25/2006 vide notification no. 32/2011 which exempted the representation services provided by CAs and CS to their clients. The noti