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

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

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

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

The March 2015 issue of Direct Tax Amicus is devoted to highlights of changes in the Union Budget 2015 and includes the proposal to amend test of residence using Place of Effective Management (POEM) concept, deferral of GAAR by 2 years, abolition of wealth tax, clarity on allowance of bal

The article in the February 2015 issue of Direct Tax Amicus explores the controversy on allowability of depreciation in a finance lease transaction in the light of revised accounting standards to be notified by the Indian Government. The clarification issued by the Central Board of Direct

The issue of taxation of share holder activity which sans clarification by CBDT, is often subject of dispute forms the basis of discussion in the Article section of the January 2015 issue of Direct Tax Amicus. Central purchasing authority not being beneficial owner for purpose of DTAA, taxab

The December 2014 issue of Direct Tax Amicus features an article on taxation of Engineering, Procurement and Construction (EPC) contracts which involve complex issues like existence of Permanent Establishment (PE), whether offshore supplies are taxable as FTS and transfer pricing issues. Rat

The highlight of the November 2014 issue of Direct Tax Amicus is the discussion on transfer pricing issues as regards contract research centres in India , featured in the Article Section. The tax-payer friendly instructions issued by CBDT and clarification regarding threshold limit to approa

The article on doing business in India through liaison office (LO), in the October 2014 issue of Direct Tax Amicus highlights the need for vigilance in structuring the format of LO, while applicability of transfer pricing provisions to issue of shares, guarantee being an international transa