Section 281 of the Income Tax Act, 1961 empowers the Department to declare a transfer of an asset as void where the transferor, during the pendency of any proceedings under the IT Act or completion thereof...
The drastic difference in income-tax treatment of both the instruments – Life Insurance Policies and Annuities, requires closer examination of their meaning to distinguish one from another.
This article in this issue of Direct Tax Amicus seeks to analyze the applicability of the non-discrimination article in tax treaties on disallowance of expenses on payment made to non-residents without withholding...
The article in this issue of Direct Tax Amicus discusses a recent ruling of the Delhi Appellate Tribunal in the case of Prism Scan Express Private Limited.
The article in this issue of Direct Tax Amicus discusses the issue of attribution of profits in case of losses at the global level, which has once again gathered spotlight as the Delhi High...
The article in this issue of Direct Tax Amicus examines as to whether in case of fresh issuance or allotment of shares, be it Equity Shares or Preference Shares, Section 56(2)(x) of the Income Tax...
The Supreme Court recently passed a judgment, in favour of the Revenue department, interpreting the Most Favoured Nation (‘MFN’) clause present in various Double Taxation Avoidance Agreements (‘DTAAs’).
The article in this issue of Direct Tax Amicus discusses the adverse impact, under the Income Tax Act, 1961, of conversion of outstanding loan to equity.
The article in this issue of Direct Tax Amicus seeks to examine the question as to whether treaty benefits should at all be provided if the non-resident seller of shares does not have much commercial substance.
The Bombay High Court has recently held that the timelines for passing an assessment order specified in Section 153 of the Income Tax Act, 1961 are not to be extended in cases where the assessee takes the Dispute Resolution Panel route and the final assessment order under Section 144C(13) has to be passed