Direct Tax Amicus of September 2015 issue covers an article pertaining the analysis of consortium model and how it has now gained popularity, whereby companies usually collaborate and jointly bid for government projects.
Notification & Circular portion of Direct Tax Amicus contains, CBDT’s guidance note in which it covers the explanation on how to determine whether a person is a Reporting Financial Institution or not, and how should they determine which financial accounts to review. Further rules for furnishing statement of reportable accounts as per Section 285BA have been notified and the same is also included in this portion.
Ratio Decidendi of this Amicus covers interesting case law like Punjab & Haryana High Court ruling that a person can be treated as Mauritius resident if he is ‘liable to taxation therein’ as the expression is not synonymous with ‘actually taxed therein’ and Delhi High Court order holding that BPO and KPO are not comparable sectors for ALP determination. Two important orders passed by ITAT Pune & Mumbai are also covered under this section.
September, 2015/Issue-14