DTAA & International Taxation: India Treaty Network, Section 90 & 91, MLI Impact

India’s DTAA Network: Key Treaties and Withholding Rates

Overview of India’s Treaty Network

India has one of the most extensive DTAA networks among developing countries, with comprehensive agreements covering over 95 jurisdictions. India’s DTAAs broadly follow the UN Model Tax Convention (which preserves greater source-country taxing rights) rather than the OECD Model (which favours residence-country taxation), reflecting India’s position as primarily a capital-importing country.

India’s treaty network includes DTAAs with all major trading and investment partners:

• Americas: USA, Canada, Brazil, Mexico
• Europe: UK, Germany, France, Netherlands, Switzerland, Luxembourg, Ireland, Belgium, Italy, Spain, Sweden, Denmark, Norway, Finland, Austria, Cyprus, Poland, Czech Republic, Hungary, Russia
• Asia-Pacific: Singapore, Japan, South Korea, China, Australia, New Zealand, Malaysia, Thailand, Indonesia, Vietnam, Philippines, Sri Lanka, Bangladesh, Nepal
• Middle East & Africa: UAE, Saudi Arabia, Qatar, Oman, Kuwait, Israel, South Africa, Kenya, Ethiopia, Mauritius

Withholding Tax Rates Under Major DTAAs

The following table summarises the withholding tax rates under India’s most commonly invoked DTAAs (rates are on gross payments unless otherwise stated). These rates must be read subject to MLI modifications where applicable:

Country	Dividends	Interest	Royalties	FTS
USA	15%/25%	15%	15%	15%
UK	15%/20%	15%	15%	15%
Singapore	10%/15%	15%	10%	10%
Mauritius	5%/15%	7.5%	15%	N/A (no FTS article)
Netherlands	10%	10%	10%	10%
Germany	10%	10%	10%	10%
Japan	10%	10%	10%	10%
UAE	10%	12.5%	10%	10%
Canada	15%/25%	15%	10%/15%	10%/15%
Australia	15%	15%	10%	10%

Note: These are indicative rates. Actual rates depend on the specific article, conditions (e.g., beneficial ownership, shareholding thresholds for reduced dividend rates), and MLI modifications. Always verify the current treaty text and MLI position before application.

Section 90: Treaty Application and the “More Beneficial” Rule

Section 90(2): Domestic Law vs Treaty — Whichever is More Beneficial

Section 90(2) of the Income Tax Act provides the foundational rule for DTAA application:

“Where the Central Government has entered into an agreement with the Government of any country outside India… for granting relief of tax, or for avoidance of double taxation… then, in relation to the assessee to whom such agreement applies, the provisions of this Act shall apply to the extent they are more beneficial to that assessee.”

This means the taxpayer can choose to be governed by either the provisions of the Income Tax Act or the DTAA, whichever is more beneficial. The comparison is done provision-by-provision (article-by-article), not as a whole. For example, a non-resident can claim the DTAA rate for royalties (if lower than the domestic rate) while being governed by the domestic law for capital gains (if the DTAA provides for source-country taxation at a higher rate).

Section 90(4) and (5): TRC and Form 10F Requirements

To claim DTAA benefits, the non-resident must satisfy two documentary requirements:

1. Tax Residency Certificate (TRC) — Section 90(4): A certificate of residence issued by the tax authority of the country of which the non-resident claims to be a resident. The TRC must be obtained from the foreign government and must contain the prescribed particulars (name, status, nationality/incorporation, tax identification number, residential status, period for which the certificate is applicable, and address)
2. Form 10F — Rule 21AB: In addition to the TRC, the non-resident must furnish Form 10F (available for electronic filing on the income tax e-filing portal) containing additional information such as PAN status in India, address in the country of residence, and whether the non-resident is liable to tax by reason of domicile, residence, or any other criterion of a similar nature

Consequence of non-compliance: Without a valid TRC, the non-resident cannot claim DTAA benefits. The Supreme Court in Azadi Bachao Andolan v. Union of India (2003) 263 ITR 706 upheld the validity of TRCs as sufficient evidence of residence, though this position has been modified for substance requirements post-MLI and GAAR.

Section 91: Unilateral Relief Where No DTAA Exists

When Section 91 Applies

Section 91 provides relief to an Indian resident who has earned income in a country with which India does not have a DTAA, and that income has been taxed in both India and the foreign country. The relief is computed as follows:

Relief = Lower of:

• (a) Indian tax payable on the doubly-taxed income (computed at the average rate of Indian tax on total world income)
• (b) Tax paid in the foreign country on the doubly-taxed income

The relief is available only if:

• The income accrued or arose in the foreign country
• The income has been taxed in the foreign country (tax must have been actually paid, not merely payable)
• The corresponding income is also included in the assessee’s Indian return

Section 91 vs DTAA Relief: Key Differences

Parameter	Section 90 (DTAA Relief)	Section 91 (Unilateral Relief)
Applicability	Countries with which India has a DTAA	Countries with which India has no DTAA
Available to	Both residents and non-residents	Indian residents only
Type of relief	Exemption method or credit method (as per treaty)	Credit method only (lower of Indian or foreign tax)
Rate benefit	May provide reduced withholding rates in the source country	No rate benefit — relief is only against Indian tax
Documentary requirement	TRC + Form 10F	Proof of foreign tax payment

Permanent Establishment (PE): The Gateway to Source-Country Taxation

What Constitutes a PE Under India’s DTAAs

The concept of Permanent Establishment is central to international taxation. A foreign enterprise is taxable in India on its business profits only if it carries on business through a PE in India. Most India DTAAs define PE to include:

1. Fixed Place PE (Article 5(1)): A fixed place of business through which the business of the enterprise is wholly or partly carried on — includes a place of management, a branch, an office, a factory, a workshop, a mine, an oil or gas well, a quarry, or any other place of extraction of natural resources
2. Construction PE (Article 5(3)): A building site, construction, assembly, or installation project (or supervisory activities in connection therewith) that continues for a period exceeding the threshold specified in the DTAA (typically 6-12 months, varying by treaty)
3. Service PE (Article 5(3)(b) or separate sub-paragraph): Furnishing of services (including consultancy services) within India through employees or other personnel for a period or periods aggregating more than a specified number of days (typically 90-183 days) within any 12-month period. Not all DTAAs contain a Service PE clause
4. Dependent Agent PE (Article 5(5)): A person acting in India on behalf of the foreign enterprise who has and habitually exercises the authority to conclude contracts in the name of the enterprise, or who maintains a stock of goods for delivery on behalf of the enterprise

MLI Modifications to PE Definition

The MLI has introduced significant modifications to PE rules for India’s Covered Tax Agreements (CTAs):

• Article 12 — Artificial Avoidance of PE through Commissionnaire Arrangements: Expands the Dependent Agent PE definition to include persons who habitually play the principal role in concluding contracts that are routinely concluded without material modification by the enterprise, even if the person does not formally conclude contracts in the enterprise’s name. India has adopted this provision
• Article 13 — Artificial Avoidance of PE through Specific Activity Exemptions: Provides that the preparatory/auxiliary exclusions (Article 5(4) of the OECD/UN Model) apply only if the activities are genuinely preparatory or auxiliary. India has adopted Option A, which requires that each listed activity must be of a preparatory or auxiliary character
• Article 14 — Splitting-Up of Contracts: Anti-fragmentation rule to prevent enterprises from splitting a single contract into multiple shorter contracts to avoid the construction PE threshold. India has adopted this provision

Treaty Shopping, GAAR, and Anti-Abuse Provisions

Treaty Shopping: The Historical Context

Treaty shopping refers to the practice where a resident of a third country (Country C) routes investments into India through an entity in a treaty country (Country T) to avail of the beneficial DTAA rates between India and Country T. The India-Mauritius DTAA was the most prominent example — investments from various countries were routed through Mauritian entities to claim capital gains exemption under the India-Mauritius DTAA.

The Supreme Court in Union of India v. Azadi Bachao Andolan (2003) 263 ITR 706 upheld treaty shopping through Mauritius, holding that a TRC issued by the Mauritius authorities was sufficient evidence of residence and that India could not go behind the TRC to question the substance of the entity. This was a watershed decision that legitimised the Mauritius route for nearly two decades.

The 2016 India-Mauritius Protocol Amendment

The 2016 Protocol amending the India-Mauritius DTAA fundamentally changed the capital gains taxation framework:

• Pre-01-04-2017 investments: Shares acquired before 1 April 2017 are grandfathered — capital gains on their transfer remain exempt under Article 13(4) of the original DTAA
• 01-04-2017 to 31-03-2019 (transition period): Capital gains were taxable in India at 50% of the domestic rate, subject to a Limitation of Benefits (LOB) clause requiring the Mauritian entity to demonstrate that it was not a shell company, had expenditure on operations of at least Rs.27 lakhs in the preceding 12 months, and was not controlled by residents of a third state
• Post-01-04-2019: Full source-country taxation — capital gains on shares are taxable in India at full domestic rates, rendering the Mauritius route ineffective for capital gains purposes

India-Singapore DTAA: Third Protocol (2017)

The India-Singapore DTAA was also amended in 2017 (Third Protocol, effective 01-04-2017) to align with the Mauritius amendment. Capital gains on shares acquired on or after 1 April 2017 are taxable in India at domestic rates. The LOB clause under Article 24A of the India-Singapore DTAA requires the Singapore entity to satisfy a “shell/conduit company” test and have an annual expenditure of at least S$200,000 in the preceding 24 months.

General Anti-Avoidance Rule (GAAR) — Sections 95-102

GAAR, introduced effective from AY 2018-19, provides the Indian tax authorities with a powerful tool to deny treaty benefits where an arrangement’s main purpose (or one of the main purposes) is to obtain a tax benefit. Key features:

• Impermissible Avoidance Arrangement (IAA): An arrangement whose main purpose is to obtain a tax benefit and which (a) creates rights/obligations not ordinarily created between arm’s length parties, (b) results in misuse or abuse of the provisions of the Act, (c) lacks commercial substance, or (d) is not carried out in a bona fide manner
• Commercial substance test (Section 97): An arrangement is deemed to lack commercial substance if it involves round-trip financing, use of an accommodating party, location of an asset or transaction unrelated to the arrangement, or a transaction with no significant effect on business risks/net cash flows apart from the tax benefit
• Threshold: GAAR applies where the tax benefit from the arrangement exceeds Rs.3 crores in an assessment year (Rule 10U)
• Grandfathering: Investments made before 01-04-2017 are not subject to GAAR (CBDT Circular No. 7/2017 dated 27-01-2017)
• Approval hierarchy: The AO must refer a proposed GAAR invocation to the Principal Commissioner, who refers it to an Approving Panel (comprising a Chairman who is a retired High Court judge, one CBDT member, and one Principal Chief Commissioner)

Principal Purpose Test (PPT) Under MLI — Article 7

The MLI’s Article 7 introduces the Principal Purpose Test as a minimum standard for all Covered Tax Agreements. The PPT provides that a DTAA benefit shall not be granted in respect of an item of income if it is reasonable to conclude that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit. India has adopted the PPT (Article 7(1)) as a standalone anti-abuse rule without the simplified LOB (Article 7(4)).

The PPT has a lower threshold than GAAR — it requires only that obtaining the treaty benefit was “one of the principal purposes” (not the “main purpose” as in GAAR). This means the PPT can be invoked even where GAAR may not apply due to its higher threshold.

Key Treaty Issues: Royalties, FTS, and Capital Gains

Royalties and Fees for Technical Services (FTS)

The taxation of royalties and FTS is one of the most litigated areas in India’s international tax jurisprudence. Key issues:

• “Make available” clause: Several India DTAAs (notably with USA, UK, Singapore, and Canada) contain a “make available” condition for FTS — the service must make available technical knowledge, experience, skill, know-how, or processes to the recipient. If the service does not transfer lasting knowledge (i.e., the recipient cannot apply it independently without the service provider), it does not qualify as FTS. The Karnataka High Court in CIT v. De Beers India Minerals Pvt. Ltd. (2012) 346 ITR 467 held that management support services that did not make available any technical knowledge were not FTS under the India-UK DTAA
• Software payments: The Supreme Court in Engineering Analysis Centre of Excellence Pvt. Ltd. v. CIT (2021) 432 ITR 471 held that payments for the use of shrink-wrap/off-the-shelf software are not “royalties” under the Copyright Act or under most DTAAs, as they do not involve transfer of the copyright but merely a right to use the copyrighted article
• Equalisation Levy: Introduced by Finance Act 2016, the Equalisation Levy at 6% applies to payments for online advertising and related services to non-residents (Section 165-174 of Finance Act 2016). The scope was expanded in 2020 to a 2% levy on e-commerce operators, but this was withdrawn with effect from 01-08-2024 by the Finance (No. 2) Act, 2024

Capital Gains on Indirect Transfers — Section 9(1)(i) Explanation 5

Following the Vodafone International Holdings BV v. Union of India (2012) 341 ITR 1 (SC) decision (which held that India could not tax offshore transfers of shares), the Finance Act 2012 introduced Explanation 5 to Section 9(1)(i), deeming capital gains on transfer of shares of a foreign company to be taxable in India if such shares derive their value substantially from assets located in India. “Substantially” is defined as more than 50% of the value of assets of the foreign company being situated in India.

This indirect transfer provision overrides DTAA protections to the extent that the DTAA does not specifically cover indirect transfers. Many India DTAAs (including India-Mauritius post-2016 and India-Singapore post-2017) now include provisions permitting India to tax indirect transfers.

The MFN Clause: Current Status After Nestle SA

What is the MFN Clause?

Several India DTAAs contain a Most Favoured Nation (MFN) clause in the Protocol, providing that if India enters into a DTAA with a third country (being an OECD member) with a lower rate of tax on dividends, interest, royalties, or FTS, the lower rate shall automatically apply to the DTAA containing the MFN clause. DTAAs with MFN clauses include those with France, Netherlands, Sweden, Spain, Hungary, Belgium, and Switzerland (for specific articles).

The Supreme Court’s Decision in Nestle SA (2023)

The Supreme Court in Assessing Officer (International Taxation) v. Nestle SA (2023) SLP (Civil) No. 17756/2021 held that:

• The MFN clause in the India-Netherlands Protocol is not self-executing
• It requires a separate notification under Section 90(1) by the Central Government for the reduced rate to take effect
• Until such notification is issued, the original treaty rate (not the MFN-reduced rate) applies
• The third country must have been an OECD member at the time of signing the DTAA with India (not merely at the time the MFN clause is sought to be invoked)

This decision reversed the position taken by several Tribunals and the Delhi High Court, which had held the MFN clause to be self-executing. Post-Nestle SA, the practical impact is that the MFN clause in India DTAAs is largely ineffective until the Central Government issues specific notifications — which, as of March 2026, have not been issued for most MFN treaties.

Section 195: TDS on Payments to Non-Residents

Obligation and Computation

Section 195 mandates that any person responsible for paying to a non-resident any sum chargeable to tax under the Act shall deduct TDS at the rates in force. Key aspects:

• No threshold: Unlike domestic TDS provisions (Section 194C, 194J, etc.), Section 195 has no monetary threshold — TDS applies on the entire amount, even Rs.1
• Rate: TDS is deducted at the rates prescribed in the Finance Act for the relevant year, or the DTAA rate if the non-resident furnishes a valid TRC and Form 10F and the DTAA rate is lower
• Grossing up: If the payer bears the tax (net-of-tax arrangement), the payment must be grossed up for TDS computation — Section 195A
• Application for lower TDS — Section 195(2)/(3): The non-resident or the payer can apply to the AO for a certificate for lower TDS or nil TDS if the income is not chargeable to tax in India (e.g., due to DTAA PE protection) or is chargeable at a lower rate
• Section 195(6) — Form 15CA/15CB: Every remittance to a non-resident requires filing Form 15CA electronically. For remittances exceeding Rs.5 lakhs (other than those specifically listed as non-taxable in Rule 37BB), a CA certificate in Form 15CB is also required

Common Section 195 Issues

• Characterisation of payments: Whether a payment to a non-resident constitutes business income (taxable only if PE exists), royalties, FTS, or capital gains determines the TDS rate and the DTAA article applicable
• Reimbursement of expenses: The Supreme Court in GE India Technology Centre (2010) held that TDS under Section 195 applies only to the “income component” of the payment, not the entire gross payment. Reimbursement of actual out-of-pocket expenses without any mark-up is generally not subject to TDS, though this requires careful documentation
• Non-resident with PE: If the non-resident has a PE in India and the income is attributable to the PE, the PE files an Indian return and pays tax directly. TDS may not be required if the AO issues a nil/lower TDS certificate under Section 195(3)

Mutual Agreement Procedure (MAP) and Advance Pricing Agreements (APA)

MAP — Article 25 of DTAAs

The Mutual Agreement Procedure allows competent authorities of two treaty countries to resolve disputes arising from taxation not in accordance with the DTAA. MAP can be invoked for:

• Transfer pricing adjustments that result in double taxation
• PE profit attribution disputes
• Characterisation of income (royalty vs business income, etc.)
• Residency tie-breaker disputes

India’s Competent Authority for MAP is the Joint Secretary (FT&TR-I), CBDT. MAP applications must be filed within the time limit specified in the DTAA (typically 3 years from the first notification of the action giving rise to taxation not in accordance with the DTAA). India has entered into MAP arrangements with several countries and resolved hundreds of cases, particularly in the transfer pricing domain.

Advance Pricing Agreements (APA) — Section 92CC-92CD

An APA is a prospective agreement between the taxpayer and the CBDT (or between the taxpayer, CBDT, and a foreign competent authority for bilateral/multilateral APAs) determining the transfer pricing methodology for international transactions for a maximum period of 5 years (with rollback for 4 preceding years). APAs provide certainty, reduce litigation, and prevent double taxation. India’s APA programme, administered by the CBDT’s APA Directorate, has signed over 500 APAs since its inception in 2012.

BEPS and India’s Position

India’s Adoption of BEPS Recommendations

India has been an active participant in the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS). Key BEPS actions adopted by India:

• Action 1 (Digital Economy): Equalisation Levy (6% on online advertising, 2% on e-commerce — the latter withdrawn from 01-08-2024); Significant Economic Presence (SEP) concept under Section 9(1)(i) Explanation 2A (though operationalisation deferred pending Pillar One outcome)
• Action 5 (Harmful Tax Practices): Exchange of tax rulings through spontaneous exchange of information
• Action 6 (Treaty Abuse): PPT adopted through MLI Article 7; LOB clauses in renegotiated DTAAs
• Action 7 (PE Avoidance): Expanded PE definition through MLI Articles 12-15
• Action 8-10 (Transfer Pricing): Three-tiered TP documentation (Master File, Local File, Country-by-Country Report) under Sections 92D/92E and Rules 10DA/10DB
• Action 13 (CbCR): Country-by-Country Reporting for MNE groups with consolidated revenue exceeding Rs.5,500 crores (EUR 750 million equivalent)
• Action 14 (MAP): Commitment to resolve MAP cases within 24 months average timeframe
• Action 15 (MLI): Signed and ratified the MLI covering 93 DTAAs

Pillar Two — Global Minimum Tax

The OECD/G20 Inclusive Framework’s Pillar Two establishes a global minimum effective tax rate of 15% for MNE groups with consolidated revenues exceeding EUR 750 million. India has not yet enacted domestic legislation implementing Pillar Two (GloBE Rules — Income Inclusion Rule (IIR), Undertaxed Profits Rule (UTPR), or Qualified Domestic Minimum Top-up Tax (QDMTT)). However, several jurisdictions that are key investment routes for India (notably the EU, UK, Japan, South Korea, and Australia) have enacted or are in the process of enacting Pillar Two rules, which will impact Indian MNE groups and subsidiaries of foreign MNEs in India.

Foreign Tax Credit — Rule 128

Where an Indian resident has paid tax in a foreign country (whether under a DTAA or in a non-treaty country), the credit for such foreign tax is governed by Rule 128 of the Income Tax Rules, 1962:

• The credit is available in the year in which the corresponding income is offered to tax in India
• The credit is the lower of the tax payable in India on the foreign income (at the Indian average rate) or the foreign tax paid
• Credit is available only if the assessee furnishes Form 67 on or before the due date of filing the return (this requirement has been relaxed — Form 67 can now be filed on or before the end of the relevant assessment year, even after the due date of the return)
• Disputed foreign tax: Where foreign tax has been disputed and is pending adjudication, the credit may be claimed provisionally and adjusted upon final determination
• The credit must be claimed on a country-by-country and income-by-income basis — aggregation across countries is not permitted

Our Pricing for International Taxation Services

Service	Scope	Pricing (INR)
DTAA treaty analysis and advisory	Treaty application, rate determination, MLI impact assessment	From Rs.25,000
PE risk assessment	Fixed place PE, service PE, agent PE analysis with MLI overlay	From Rs.50,000
Section 195 TDS advisory	Payment characterisation, DTAA rate determination, Section 195(2) application	From Rs.15,000 per transaction
Form 15CA/15CB certification	CA certificate for remittance to non-residents	From Rs.5,000 per certificate
Transfer pricing documentation	Master File, Local File, CbCR, Form 3CEB	From Rs.75,000
MAP application support	Application drafting, representation before Competent Authority	From Rs.2,00,000
International tax structuring	Inbound/outbound investment structuring, holding company analysis	From Rs.1,00,000
GAAR/PPT risk assessment	Anti-abuse provision analysis for existing and proposed structures	From Rs.50,000

For a detailed engagement proposal, visit Virtual Auditor pricing or call +91 99622 60333.

Frequently Asked Questions

1. What is a DTAA and how does it benefit taxpayers?

A DTAA is a bilateral treaty under Section 90 of the Income Tax Act between India and another country that prevents the same income from being taxed in both countries. DTAAs provide: reduced withholding tax rates on dividends, interest, royalties, and FTS; protection from source-country taxation of business profits if no PE exists; mechanisms for resolving disputes through MAP; and exchange of information between tax authorities. Under Section 90(2), the taxpayer can apply either the domestic law or the DTAA, whichever is more beneficial.

2. How many DTAAs has India signed?

India has comprehensive DTAAs with over 95 countries, covering all major trading and investment partners across the Americas, Europe, Asia-Pacific, Middle East, and Africa. Key treaties include those with USA, UK, Singapore, Mauritius, Netherlands, UAE, Germany, Japan, France, Canada, and Australia. India also has limited agreements (covering airline/shipping profits or information exchange) with additional jurisdictions.

3. What is the Multilateral Instrument (MLI) and how does it affect India’s DTAAs?

The MLI is a multilateral convention under the OECD BEPS project that modifies existing bilateral DTAAs without requiring bilateral renegotiation. India signed the MLI on 7 June 2017 and ratified it on 25 June 2019. India has listed 93 DTAAs as Covered Tax Agreements. The MLI introduces the Principal Purpose Test (PPT) to counter treaty shopping, expands the PE definition to address commissionnaire arrangements and contract splitting, and modifies the specific activity exemptions for PE. Each DTAA must be read with its MLI modifications.

4. What is a Tax Residency Certificate (TRC) and when is it required?

A TRC is mandatory under Section 90(4) for any non-resident claiming DTAA benefits in India. It must be issued by the tax authority of the country of residence and contain prescribed particulars (name, status, nationality, TIN, residential status, period, and address). In addition, the non-resident must file Form 10F on the e-filing portal. Without a valid TRC and Form 10F, DTAA benefits cannot be claimed and the domestic law withholding rates apply.

5. What is the Most Favoured Nation (MFN) clause in India’s DTAAs?

Certain India DTAAs (France, Netherlands, Sweden, Spain, Hungary, Belgium, Switzerland) contain an MFN clause providing that if India signs a DTAA with a third OECD member country at a lower rate, the lower rate automatically applies. However, the Supreme Court in Nestle SA (2023) held that the MFN clause is not self-executing — it requires a separate notification under Section 90(1) by the Central Government. Until such notification is issued, the original treaty rate (not the MFN-reduced rate) applies.

6. What is the difference between Section 90 and Section 91?

Section 90 provides double taxation relief through bilateral DTAAs — available to both residents and non-residents, with the “more beneficial” rule allowing the taxpayer to choose between domestic law and DTAA. Section 91 provides unilateral relief only to Indian residents who earn income in countries with which India has no DTAA — relief is limited to the lower of the Indian tax or the foreign tax on the doubly-taxed income. Section 91 relief requires proof that tax has been actually paid in the foreign country.

7. How much does international taxation advisory cost?

At Virtual Auditor, DTAA treaty analysis starts from Rs.25,000. PE risk assessment from Rs.50,000. Section 195 TDS advisory from Rs.15,000 per transaction. Form 15CA/15CB certification from Rs.5,000. Transfer pricing documentation from Rs.75,000. MAP application support from Rs.2,00,000. International tax structuring from Rs.1,00,000. Contact CA V. Viswanathan at +91 99622 60333 for a customised engagement proposal.

Related Resources

• Form 15CA/15CB Filing Guide
• Income Tax Appeal: Form 35 & CIT(A) Process
• Income Tax Appeal Services: CIT(A) & ITAT
• Rule 11UA Valuation for Income Tax
• FEMA Compliance Services
• Transfer Pricing Services
• Valuation Services
• Income Tax India (Official)
• ICAI — Institute of Chartered Accountants of India
• Reserve Bank of India
• Ministry of Corporate Affairs

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