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

The September 2014 issue of Direct Tax Amicus covers criteria for selection of cases for scrutiny (Circular), decision on applicability of transfer pricing provisions to secondary adjustments, eligibility of IT enabled HR services for Section 10A deduction, taxability of services rendered by

The article in August 2014 issue of Direct Tax Amicus discusses the possible unequal treatment of non-resident on restriction of disallowance to 30% in case of TDS defaults on payments to residents. The clarification on taxation of AIFs having status of non-charitable trusts is covered under