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Direct Tax Amicus: September 2023

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.

Direct Tax Amicus: August 2023

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

Direct Tax Amicus: July 2023

The Finance Act, 2021 substituted the provisions of reassessment under the Income-tax Act, 1961. Under the new reassessment provisions, the concept of ‘reason to believe’ has been substituted with ‘information’ which suggests that the income has escaped assessment.

Direct Tax Amicus: June 2023

The article in this issue of Direct Tax Amicus discusses a recent decision of the Supreme Court in the case of Saraf Exports v. CIT, wherein the Apex Court has held that export incentives like Duty Drawback and DEPB will not qualify as first-degree nexus for the purposes of claim of deduction under Section 80-IB of the Income Tax Act, 1961.

Direct Tax Amicus: May 2023

The article in this issue of Direct Tax Amicus discusses elaborately the recent amendment in Section 11 of the Income Tax Act, 1961 vide Finance Act, 2023, with effect from 1 April 2024. Noting that a charitable entity was allowed to accumulate a maximum of 15% of its income...

Direct Tax Amicus: April 2023

The article in this issue of Direct Tax Amicus discusses the labyrinth of exemption available to charitable institutes under the Income Tax Act, 1961. Considering the changing landscape of the exemption regime, right from Finance...

Direct Tax Amicus: March 2023

Amongst various tax amendment proposals announced this year, proposal for taxing ‘cash’ benefits and perquisites is likely to have a wide-reaching impact on the taxpayers, especially in...

Direct Tax Amicus: February 2023

Income derived from Trust property has been exempt under Income-tax laws since the Act of 1886. Tracing the legislative history in respect of income from property held under trust, the author examines amendments made by Finance Act, 1970;

Direct Tax Amicus: January 2023

It gives me great pleasure to address you through this 100th issue of Direct Tax Amicus. I have always believed that the wealth of knowledge should be shared.

Direct Tax Amicus: December 2022

The charitable trusts/institutions enjoy substantial income-tax benefits and hence are often subject to detailed scrutiny to ensure that commercial concerns are kept outside the boundaries of the tax-exempt status.