This article provides a comprehensive summary of the efforts undertaken by OECD in addressing the issues relating to the Tax Challenges Arising from the Digitalisation of the Economy. The article then discusses the intricacies of the proposed Unified Approach issued by OECD Secretariat and endorsed by the OECD Inclusive Framework on Base Erosion and Profit Shifting Project.
To enable ease of doing business, the taxation framework for Alternative Investment Funds (AIF) provide pass-through status to profits of the AIF (Category I and Category II) to the investors under which any income, barring business income, earned by AIFs would be exempt in the hands of such AIFs, and taxable directly in the hands of its investor(s).
This article introduces a fresh perspective to the taxation of offshore indirect transfer of immovable property. It argues that such offshore indirect transfer can be taxed under the specific anti-abuse provisions of Section 2(47)(vi) of the Income-tax Act 1961 as they stood prior to the retrospective amendments brought into the Act through the Finance Act 2012.
Transfer Pricing provisions in Chapter X of the I-T Act 1961 entitled Special Provisions Relating to Avoidance of Tax enables the Transfer Pricing Officer in determining the Arm’s Length Price (ALP) in relation to an international transaction between Associated Enterprises commonly referred as controlled transaction, by using the Most Appropriate Method (MAM) from the prescribed methods under Section 92C (1) of the Act.
Statements on oath are recorded by officers u/s 131(1) and 132(4) of Income Tax Act. The article analyses with the help of judicial pronouncements how to record proper statements backed by credible evidence without any threat or coercion. These statements serve as a crucial piece of evidence necessary for making sustainable additions in assessment.
Legal forums at various levels have been annulling assessment orders framed u/s 153C(1) in case of ‘other person’ (the non-searched person) for some of the assessment years out of a totalpermissible period of six assessment years on the ground that they fall beyond the relevant period if reckoned from the year of recording satisfaction/handing over of seized material, as opposed to the statutory provisions, which require the reckoning of the aforesaid period from the year of initiation of search itself,in the same manner as provided u/s 153A.
Learn how to efficiently file Form GSTR-4 (Annual Return) using the offline utility tool. Gain insights into the step-by-step process, from downloading the utility to uploading the JSON file on the GST Portal. Author: Dhara D. Khakharia.
Article contains FAQs related to Form GSTR-4 (Annual Return) Offline Utility. Faqs are divided in 6 parts which includes About Form GSTR-4 (Annual Return) Offline Utility, Download Form GSTR-4 (Annual Return) Offline Utility, Download the Generated JSON File, Worksheet Tabs in Form GSTR-4 (Annual Return) Offline Utility, Entering and Validating Details in Offline Utility, Upload […]
Tariff Notification No. 70/2020-Customs (N.T.), Dated: 07.08.2020 in respect of Fixation of Tariff Value of Edible Oils, Brass Scrap, Poppy Seeds, Areca Nut, Gold and Silver MINISTRY OF FINANCE (Department of Revenue) (CENTRAL BOARD OF INDIRECT TAXES AND CUSTOMS) Notification No. 70/2000-CUSTOMS (N.T.) New Delhi, the 7th August, 2020 S.O. 2649(E).—In exercise of the powers […]
Namaskar Enterprise Vs Commissioner of Goods & Service Tax (Gujarat High Court) A perusal of the aforesaid Sub-Section-2 of Section 83 makes it abundantly clear that the provisional attachment would cease to have effect after the expiry of a period of one year from the date of the order made under Sub-Section-1. Although no specific […]
