Liaison Office as PE under India-US DTAA By Tanmay Bhatnagar A liaison office under the Foreign Exchange Regulations is not supposed to undertake any comme
Conversion of company to LLP - Capital gains tax implications By Prerana Priyanshu Conversion into Limited Liability Partnership (LLP) is becoming a popular choice for many existing companies. One of the cru
Privity of contract and locus with a source of income – A test of diversion by overriding title By Prachi Goel & Saurav Sood Deduction of allocation of distributable surplus as expend
Amalgamation – Action in concert for tax benefit? By Subhashree R In a recent case before NCLT, the income tax department objected to the scheme of amalgamation proposed by the petiti
Section 92 of the Income-tax Act, 1961 provides that any income arising from an international transaction shall be computed, having regard to the arm’s length price.
Deemed Associated Enterprises - Interplay between Sections 92A(1) and 92A(2) By Sanmati Raonka Section 92 of the Income-tax Act, 1961 provides that any income arising from an international trans
The Authority for Advance Rulings (Income Tax) in its recent ruling in the case of FRS Hotel Group has brought a question mark on the issue of operation and management contract for hotels.
Extensive control of non-resident over Indian entity – A taxing relation By Prachi Goel and Saurav Sood The Authority for Advance Rulings (Income Tax) in its rece
The Central Government, in September 2016, introduced Income Computation and Disclosure Standards (shortly, ‘ICDS’), under the Income tax law, that would govern computation of income of an assessee under the head ‘profits or gains from business or profession’ and ‘income from other sources’ necessitated a taxpayer to take a fresh look at certain issues which were accepted as settled.
Retention money - Is recognition as contract revenue sufficient to tax it early? By Bharathi Krishnaprasad The Central Government, in September 2016, introduced I
Finance Act, 2017 amended the Income-tax Act, 1961 (‘IT Act’) to provide that the annual value of building or land appurtenant thereto which is held by the assessee as stock-in trade will be deemed to be Nil for a period of one year from the end of the financial year in which the certificate of completion is obtained in respect of such property.