01 January 0001

Direct Tax Amicus: February 2016


Artificial computation provisions – Unintended cross roads with anti-avoidance rules -

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. When the taxable income is not based on the value of transaction determined by the parties, but computed based on a statutory mechanism or presumption, the question that begs an answer is, whether ALP can be substituted to such artificially determined income…


Notifications & Circulars

  • Assessee can choose the ‘Initial assessment year’ for the purpose of Section 80-IA
  • Tax authorities to adhere to time limit of 6 months for rectification sought by assessee or deductor


Ratio Decidendi

  • TDS need not be deducted on software purchased for sale by Value Added Reseller – Delhi High Court
  • Subsidy to reduce cost of acquisition of fixed assets is revenue in nature – ITAT, Kolkata
  • Data processing qualifies for exemption under Section 10A – ITAT, Chennai


February, 2016/Issue-19 February, 2016/Issue-19

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