Supreme Court agrees with the High Courts that Income Tax Department erred in issuing reassessment notices for AYs ending before 31st March, 2021 as per old provisions even after 31st March, 2021 while the government has enacted a complete new …
Continue reading “Crux of the Supreme Court Order on Section-148 of the Income Tax”
read moreAround 90K notices for reassessment has been invalidated by various High Courts due to technical issue. #supremecourtofindia today justify the actions of the HCs. But invoking its power under Article 142 of the Indian Constitution, the Apex Court today …
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Conclusions may be drawn from the above are that the business should definitely manage these tax risk which can eat out his business completely by just becoming aware of the such situations which leads to tax risk.
read moreMultinational Enterprises (MNE) Taxation – Unilateral to Multilateral Solution to justify right of Tax of Market Jurisdictions Setting Context OECD/G20 Inclusive Framework on BEPS working on International collaboration to end tax avoidance and resolve challenges arising out of digitalization of …
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read moreRoyalty and Fee for Technical Services (FTS) Taxable on Gross Basis or Net Basis- An Analysis Setting Context for Royalty and FTS Taxability :- Income from Royalty and Fee for technical Services are generally taxable in the hands Non-resident …
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read moreForeign Tax Credit – Some key Questions Taxpayer who is Resident in India is allowed Foreign Tax Credit for the foreign taxes paid on income earned overseas by way of deduction or otherwise in the year in which the said income has …
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read moreRoyalty vs. Fee for technical services vs. Business Profit As per International tax rules for Non-Resident Taxation, specific income of Non-residents have been excluded from the business Income so as to give taxing rights to the source Countries in respect …
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read moreCommission to Overseas Agent- Is Fee for Technical Services? Commission earned by Non-resident overseas agent from an Indian Company- Whether Taxable in India? Firstly, Taxability of any income in the hands of non-resident is be determined as per the provision …
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read moreInternational collaboration to end tax avoidance Gone are the days? When a MNE incorporated in a Country, while its POEM is in a tax heaven, its production is in another jurisdiction and customers are located in some other jurisdiction, can …
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read moreRole of International Financial Services Centres’s (IFSC) in India’s Growth Story – An Unfinished Agenda It is estimated that Indian households have accumulated considerable wealth outside the country; well beyond the present limits set by RBI. The ability of Indian …
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