IT Appeal No. 9302 (Mum) of 2025 | Assessment Year 2017-18 | Decided: 26 March 2026 Underwriting commission received by a UK-resident entity from Indian companies for ADR/GDR issues constitutes consideration for assuming financial risk, not for rendering technical or consultancy services and therefore cannot be taxed in India as Fees for Technical Services under Section 9(1)(vii) of the Income-tax Act, 1961 or as Fees for Included Services under Article 13 of the India-UK DTA

CBDT has notified certain changes in Form 3CD for AY 2024-25 vide Income-tax (Fourth Amendment) Rules, 2024 dated 5th March 2024. A tabular representation of amended clauses, before and after the notification, along with brief remarks is given below - S.No . Clause Before Amendment After Amendment Remarks 1. 8a Whether the assessee has opted for taxation under section 115BA / 115BAA / 115BAB / 115BAC / 115BAD? Whether the assessee has opted for taxation under section 115BA /

Case Law Update I N THE HIGH COURT OF DELHI Hyatt International-Southwest Asia Ltd. (Appellant) v. Additional Director of Income-tax (Respondent) Judgement Delivered On - December 22, 2023, Order Released On - January 3, 2024 Advocates who appeared in this case: For the Appellant : Mr S. Ganesh, Senior Advocate with Mr U.A. Rana and Mr Himanshu Mehta, Advocates. For the Respondent : Mr Sanjay Kumar, Senior Standing Counsel for Revenue with Ms Easha Kadian, Advocate Synopsis T