Sunday , February 15, 2026 |   17:29:59 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Newsletters
 
NEWS FLASH
 
OECD unemployment rate hangs at 5% in Dec month (See Brief) I-T - Receipts from provision of flight information/data cannot be characterised as royalty, merely because assessee has applied its accumulated experience in compiling the information: ITAT (See Breaking News) DTAA - As is trite law, Fees for Technical Services, not specifically addressed in a DTAA is to be treated as business income if it relates to the ordinary business activity of the foreign AE: ITAT (See Breaking News) DTAA - Payments made to Thai company for transponder services do not amount to royalty under Article 12 of the India–Thailand DTAA, as assessee neither had possession nor control over satellite or transponders: ITAT (See Breaking News) DTAA - CBDT Instruction No. 1/2018, orders passed in scrutiny cases through e-proceedings must be digitally signed by AO; manual signing of such order is fatal procedural defect - order quashed: ITAT (See Breaking News) DTAA - Sale of software not taxable as royalty, where once core software transaction is not taxable, then related & inseparable services cannot independently be treated as Fees for Technical Services: ITAT (See Breaking News) TP - After omission of clause (i) of section 92BA vide Finance Act, 2017, expenditure transactions covered u/s 40A(2), including interest payments to related parties, ceased to be specified domestic transactions: ITAT (See Breaking News) Real Household income stagnates in G7 area in Q3 (See Brief) OECD inflation stable at 3.7% in Dec month in 2025 (See Brief) TP - Mechanical exclusion of comparables by merely relying on coordinate bench decisions, without undertaking a proper FAR analysis or recording reasons on functional dissimilarity, is unsustainable: ITAT (See Breaking News) I-T - Notice for re-assessment u/s 148 for Assessment Year 2015-16, is invalid and barred by limitation if it was issued on or after April 1, 2021: ITAT (See Breaking News) TP - As per Sec 153(4), where reference u/s 92CA was made to TPO, then time limit stands extended by another 12 months: ITAT (See Breaking News) DTAA - Receipts from bandwidth services cannot be taxed as royalty as per section 9(1)(vi) or Article 12(3) of the India-Singapore DTAA: ITAT (See Breaking News) TP - If company's financials show predominantly software development service income and it satisfies all quantitative filters, denial of inclusion merely because it provides ancillary support services is not justified: ITAT (See Breaking News) TP - ALP for benchmarking electricity transactions should include gross rate charged by State Electricity Authority, which includes mandatory charges such as demand and penal charges: ITAT (See Breaking News) DTAA - Provisions of the DTAA are not triggered by DDT paid by a domestic company u/s 115-O: ITAT (See Breaking News) I-T - Proviso to Sec 149 provides that up to A.Y 2021-22 (period before amendment), period of limitation as prescribed in erstwhile provisions of Section 149(1)(b) would be applicable: ITAT (See Breaking News) I-T - Income from distribution of standardized software products by distributor, who does not own intellectual property, cannot be characterized as FTS: ITAT (See Breaking News) I-T - If international transactions between parties relating to non-exclusive distributorship and sale of software, were found to be at arm's length, no further attribution of profit can be made to PE: ITAT (See Breaking News) INTL - Interest paid u/s 201(1A) for delayed deposit of TDS is not compensatory in nature & does not qualify as allowable business expenditure u/s 37(1): ITAT (See Breaking News) INTL - Disallowance u/s 40(a)(i) sustainable where assessee paid a substantial sum to an international consultant, thereby creating an employer-employee relationship attracting TDS u/s 192: ITAT (See Breaking News) I-T - Procedure u/s 144C(1) has to be followed by Assessing Officer only if he proposes to make any variation which is prejudicial to interest of eligible assessee: ITAT (See Breaking News)
 
TII SEARCH
 
 
   
Home >>
 

Modification in the new system of approval in respect of application under section 197 of Income Tax Act
By TII News Service
Sep 02, 2019 , New Delhi

    

[F.NO.275/16/2019-IT(B)]

GOVERNMENT OF INDIA
MINISTRY OF FINANCE
DEPARTMENT OF REVENUE
CENTRAL BOARD OF DIRECT TAXES
NEW DELHI

Dated: September 02, 2019

OFFICE MEMORANDUM

Subject: Modification in the new system of approval in respect of application under section 197 of Income Tax Act

Reference may be made to the Board's Instruction No. 7 of 2009 dated 23.12.2009 vide which prior administrative approval of Commissioner of Income-Tax was prescribed for issue of certificate under section 197 of the Income -Tax Act, where the tax forgone exceeded specified thresholds. Various administrative and systematic difficulties related to such amount of revenue forgone under the newly introduced system of online application u/s 195/197 of the IT. Act 1961 in respect of non-resident taxpayers were brought to the notice of the Board. To address these difficulties, a proposal for raising the threshold of revenue forgone was made so as to balance the needs of supervisory control and expeditious grant of certificate.

2. The above matter has been examined in the Board and it has been decided to raise threshold of revenue effect for issue of certificates under section 197/195 needing approval of the Commissioner of Income Tax (Intl. Taxation) to Rs. 10 Crore. This threshold will be applicable for all stations in respect of all applications of non-resident taxpayers either pending as on date or filed hereafter.

This issues with the approval of the Chairman, CBDT.

(Naveen Kapoor)
Under Secretary to the Govt. of India

 
 
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI TII
  • DTAA
  • Circulars (I-T Act, 1922)
  • Limited Treaties
  • Other Treaties
  • TIEAs
  • Notifications
  • Circulars
  • Relevant Sections of I-T Rules,1962
  • Instructions
  • Administrative Orders
  • DRP Panel
  • I-T Act, 1961
  • MLI
  • Relevant Portion of I-T Act,1922
  • GAAR
  • MAP
  • OECD Conventions
  • Draft Guidelines
  • DTC Bill
  • Committee Reports
  • FATCA
  • Intl-Taxation
  • Finance Acts
  • Manual on EoI
  • UN Model Taxation
  • Miscellaneous
  • Cost Inflation Index
  • Union Budget
  • Information Security Guidelines
  • APA Annual Report
  • APA Rules
  • Miscellaneous
  • Relevant Sections of Act
  • Instructions
  • Circulars
  • Notifications
  • Draft Notifications
  • Forms
  • TP Rules
  • APA FAQ
  • UN Manual on TP
  • Safe Harbour Rules
  • US Transfer Pricing
  • FEMA Act
  • Exchange Manual
  • Fema Notifications
  • Master Circulars
  • Press Notes
  • Rules
  • FDI Circulars
  • RBI Circulars
  • Reports
  • FDI Approved
  • RBI Other Notifications
  • FIPB Review
  • FEO Act
  • INTELLECTUAL PROPERTY
  • CBR Act
  • NBFC Report
  • Black Money Act
  • PMLA Instruction
  • PMLA Bill
  • FM Budget Speeches
  • Multimodal Transportation
  • Vienna Convention
  • EXIM Bank LoC
  • Manufacturing Policy
  • FTDR Act, 1992
  • White Paper on Black Money
  • Posting Policy
  • PMLA Cases
  • Transfer of Property
  • MCA Circular
  • Limitation Act
  • Type of Visa
  • SSAs
  • EPFO
  • Acts
  • FAQs
  • Rules
  • Guidelines
  • Tourist Visa
  • Notifications
  • Arbitration
  • Model Text
  • Agreements
  • Relevant Portion of I-T Act
  • I-T Rules, 1962
  • Circulars
  • MISC
  • Notification
  • About Us
  • Contact Us
  •  
     
    A Taxindiaonline Website. Copyright © 2010-2025 | Privacy Policy | Taxindiainternational.com Pvt. Ltd. OPC All rights reserved.