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Direct Tax Amicus: March 2016

With the Finance Bill 2016, the penalty regime in income-tax law is proposed to undergo a major overhaul.

Direct Tax Amicus: February 2016

With the developed economies feeling the brunt of losing tax revenues due to tax planning, provisions relating to Transfer Pricing were introduced to ensure economic value add in every jurisdiction is adequately compensated.

Direct Tax Amicus: January 2016

CBDT recently notified a draft of guiding principles for determination of PoEM of a company. PoEM has been defined to be a place where key management and commercial decisions that are necessary for the conduct of the business of an entity as a whole are, in substance, made.

Direct Tax Amicus: December 2015

Direct Tax Amicus for the month of December 2015 covers article titled ‘Situs of IP for taxing rights’. According to the author, States that want to extend their taxing power on IP holding companies should first have some understanding of the nature of IP rights.

Direct Tax Amicus: November 2015

Provisions relating to deduction of tax at source (‘TDS’) do offer the government a good tool of efficient tax recovery but unless counterbalanced with a measure like Section 197, can become a weapon of oppression.

Direct Tax Amicus: October 2015

Article in this October 2015 issue of Direct Tax Amicus titled “Month-end Provisions and Reversal – Is TDS called for?”

Direct Tax Amicus: September 2015

Direct Tax Amicus of September 2015 issue covers an article pertaining the analysis of consortium model and how it has now gained popularity, whereby companies usually collaborate and jointly bid for government projects. Notification & Circular portion of Direct Tax Am

Direct Tax Amicus: August 2015

The August, 2015 issue of Direct Tax Amicus features an article titled ‘Jurisprudence of International Tax Law’. In this article the author discusses how the Inter-Nation Equity concept has played a pivotal role in the development of international tax law as it stands today. According to

Direct Tax Amicus: July 2015

The July, 2015 issue of Direct Tax Amicus features an article on ‘Corporate Guarantee – Certainty in taxation not guaranteed!’. This article analyses tax implications of various transactions arising out of a contract of guarantee between Associated Enterprises (‘AEs&r

Direct Tax Amicus: June 2015

The June, 2015 issue of Direct Tax Amicus features an article on, International Taxation and Revenue Rule. In this article the author states that the concept of revenue rule in the nascent stage of international taxation contributed to the development of source and resident based taxation

Direct Tax Amicus: May 2015

The May, 2015 issue of Direct Tax Amicus features an article on applicability of res judicata in tax matters which discusses on certain key issues of non –applicability of doctrine of res judicata in taxation. The Circular and Instruction section covers a circular clarifying that no in

Direct Tax Amicus: April 2015

The April 2015 issue of Direct Tax Amicus features an article on compelling a non-resident to seek PAN which discusses two different decisions of the Tribunal with differing views on whether tax could be deducted at the rate prescribed in a treaty even when the non-resident does not have a P