Liaison Office as PE under India-US DTAA By Tanmay Bhatnagar A liaison office under the Foreign Exchange Regulations is not supposed to undertake any comme

Conversion of company to LLP - Capital gains tax implications By Prerana Priyanshu Conversion into Limited Liability Partnership (LLP) is becoming a popular choice for many existing companies. One of the cru

Privity of contract and locus with a source of income – A test of diversion by overriding title By Prachi Goel & Saurav Sood Deduction of allocation of distributable surplus as expend

Amalgamation – Action in concert for tax benefit? By Subhashree R In a recent case before NCLT, the income tax department objected to the scheme of amalgamation proposed by the petiti

Section 92 of the Income-tax Act, 1961 provides that any income arising from an international transaction shall be computed, having regard to the arm’s length price.

Deemed Associated Enterprises - Interplay between Sections 92A(1) and 92A(2) By Sanmati Raonka Section 92 of the Income-tax Act, 1961 provides that any income arising from an international trans

The Authority for Advance Rulings (Income Tax) in its recent ruling in the case of FRS Hotel Group has brought a question mark on the issue of operation and management contract for hotels.

Extensive control of non-resident over Indian entity – A taxing relation By Prachi Goel and Saurav Sood The Authority for Advance Rulings (Income Tax) in its rece

The Central Government, in September 2016, introduced Income Computation and Disclosure Standards (shortly, ‘ICDS’), under the Income tax law, that would govern computation of income of an assessee under the head ‘profits or gains from business or profession’ and ‘income from other sources’ necessitated a taxpayer to take a fresh look at certain issues which were accepted as settled.

Retention money - Is recognition as contract revenue sufficient to tax it early? By Bharathi Krishnaprasad The Central Government, in September 2016, introduced I