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Direct Tax Amicus: October 2018

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

Direct Tax Amicus: August 2018

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.

Direct Tax Amicus: August 2018

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

Direct Tax Amicus: July 2018

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.

Direct Tax Amicus: July 2018

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

Direct Tax Amicus: June 2018

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.

Direct Tax Amicus: June 2018

Retention money - Is recognition as contract revenue sufficient to tax it early? By Bharathi Krishnaprasad The Central Government, in September 2016, introduced I

Direct Tax Amicus: May 2018

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.

Direct Tax Amicus: March 2018

The issue of liability to deduct tax at source on reimbursement of expenditure can be traced to the difference in claim of the taxpayer and taxman.

Direct Tax Amicus: April 2018

Under OECD Model Tax Convention income from professional services was taxed in terms of Article 14 titled ‘Independent Personal Services’ However, Article 14 was deleted from the OECD MTC with effect from 29th April 2000 and the taxation of income from professional services was brought at par with taxation of business profits as provided in Article 7 of OECD MTC.

Direct Tax Amicus: February 2018

The liberal interpretation of the term ‘income’ and ‘business’ has not been wide enough to bring into the tax net certain receipts like compensation on termination of managing agency, profit from transfer of DEPB scrip, non-compete fee, etc.,

Direct Tax Amicus: January 2018

The income chargeable under the head ‘salaries’ is one of the heads of incomes which covers exhaustively, ‘payments’ made between persons in the capacity of employer and employee.