D.C. Agrawal, Advocate, has a vast experience in the field of taxation. He
served in Income Tax Department as an IRS officer for about 30 years.
Thereafter in 2005, he was elevated to Income Tax Appellate Tribunal
where he served as Accountant Member till his superannuation in July,
2011. In Income Tax Department, he served in various capacities, from
Assessing Officer, Investigating Officer and Departmental Representative
before Income Tax Appellate Tribunal and Income Tax Settlement
Commission. During his tenure as Investigating Officer in Delhi, he has
been associated with some high profilecases.
Apart from being IRS, he holds Master’s Degree in Science. He is Law
Graduate and is also a qualified Cost and Works Accountant. As an
Accountant Member of Income Tax Appellate Tribunal, he has authored
several landmark Judgments which have been published leading Tax
journals. He has also authored about 100 Articles, particularly carrying
analysis of judgments rendered by Hon’ble High Court and Income Tax
Appellate Tribunal. These Articles are published in leading journals
such as Corporate Professional Today.
Currently, he is practising as an Advocate and Consultant and also
appearing before Income Tax Appellate Tribunal and Income Tax
Settlement Commission. He has represented in several important
matters involving issues relating to do’
and International Taxation.
1-PERSONS COVERED (ARTICLE 1 OF OECD MC)
2-TAXES COVERED (ARTICLE 2 0F OECD MC)
3-GENERAL DEFINITIONS (ARTICLE 3 OF OECD MC)
4-SUBJECT TO TAX (RELATING TO ARTICLE 1 OF OECD MC)
5-SOURCE VS. RESIDENCE(ARTICLE 4 OF OECD MC)
6-PLACE OF EFFECTIVE MANAGEMENT(POEM) (RELATING TO ARTICLE 4 OF OECD MC)
7-PERMANENT ESTABLISHMENT(ARTICLE 5 OF OECD MC)
8-INCOME FROM IMMOVABLE PROPERTY (ARTICLE 6 OF OECD MC)
9-BUSINESS PROFITS (ARTICLE 7 0F OECD MC)
10-FORCE OF ATTRACTION (RELATING TO ARTICLE 7 OF OECD MC)
11-INCOME FROM SHIPPING AN AIRCRAFT BUSINESS (ARTICLE 8 OF OECD MC)
12-ASSOCIATED ENTERPRISES(ARTICLE 9 OF OECD MC)
13-TRANSFER PRICING (RELATING TO ARTICLE 9 OF OECD MC)
14-DIVIDEND (ARTICLE 10 OF OECD MC)
15-TAXATION OF INTEREST (ARTICLE 11 OF OECD MC)
16-ROYALITY (ARTICLE 12 OF OECD MC)
17-FEE FOR TECHNICAL SERVICES(RELATING TO ARTICLE 12 OF OECD MC)
18-‘MAKE AVAILABLE” (RELATING TO”FEE FOR TECHNICAL SERVICES”)
19-MAY BE TAXED”AND “MAY ALSO BE TAXED”
20-CAPITAL GAINS(ARTICLE 13 0F OECD MC)
21-INDEPENDENT PERSONAL SERVICES (ARTICLE 14 OF OECD MC)(DELETED)
22-INCOME FROM EMPLOYMENT(ARTICLE 15 OF OECD MC)
23-DIRECTOR’S FEES (ARTICLE 16 OF OECD MC)
24-ENTERTAINERS AND SPORTSPERSONS (ARTICLE 17 OF OECD MC)
25-PENSIONS (ARTICLE 18 OF OECD MC)
26-GOVERNMENT SERVICE (ARTICLE 19 OF OECD MC)
27-OTHER INCOME (ARTICLE 21 OF OECD MC)
28-STUDENTS (ARTICLE 20 OF OECD MC)
29-CAPITAL (ARTICLE 22 OF OECD MC)
30-FOREIGN TAX CREDIT (ARTICLE 23 OECD MC)
31-NON-DISCRIMINATION (ARTICLE 24 OF OECD MC)
32-TREATY SHOPPING
33-TAX SPARING
34-TAX EVASION AND TAX AVOIDANCE
35-DOUBLE TAXATION/DOUBLE NON-TAXATION
36-INTERPRETATION OF STATUTES AND TAX TREATIES
37-WITHHOLDING TAX
38-LIMITATION OF BENEFIT RULE
39-TAX HAVENS
40-TREATY OVERRIDE
41-THIN CAPITALIZATION
42-BENEFICIAL OWNERSHIP
43-MUTUAL AGREEMENT PROCEDURE (ARTICLE 25 OF OECD MC)
44-EXCHANGE OF INFORMATION (ARTICLE 26 OF OECD MC)
45-ASSISTANCE IN THE COLLECTION OF TAXES (ARTICLE 27 OF OECD MC)
46-MEMBERS OF DIPLOMATIC MISSIONS AND CONSULAR POSTS (ARTICLE 28 OF OECD MC)
47-TERRITORIAL EXTENSION(ARTICLE 29 OF OECD MC)
48-ENTRY INTO FORCE(ARTICLE 30 OF OECD MC)
49-TERMINATION(ARTICLE 31 OF OECD MC)
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