Topic

Non-Resident Taxation

2 articlesLatest July 2026
DTAA Article 12(4)(b) | 'Make Available' Test Not Triggered Without Transfer and Retention of Technical Knowledge: ITAT Mumbai
Case Law Analysis
|Income Tax Appellate Tribunal

DTAA Article 12(4)(b) | 'Make Available' Test Not Triggered Without Transfer and Retention of Technical Knowledge: ITAT Mumbai

The ITAT Mumbai ruled that fees for research management support services do not constitute Fees for Technical Services under the India-Singapore DTAA unless the recipient receives and retains transferable technical knowledge. This clarifies the boundary between advisory support and taxable technical service, impacting multinational corporations structuring intra-group support arrangements in India.

Section 44C IT Act | Overseas NRI Desk Costs Allowable as Head Office Expenditure if Executive/Administrative : ITAT Mumbai
Case Law Analysis
|Income Tax Appellate Tribunal

Section 44C IT Act | Overseas NRI Desk Costs Allowable as Head Office Expenditure if Executive/Administrative : ITAT Mumbai

ITAT Mumbai rules that expenses incurred by an overseas NRI desk for Indian operations qualify as deductible head office expenditure under Section 44C of the Income Tax Act, provided they are executive or administrative in nature. The ruling clarifies the scope of allowable deductions for multinational banks and non-resident entities, impacting tax compliance and planning for cross-border operations.

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