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Kshitij Agrawal

Latest Posts by Kshitij Agrawal

Section 12AB & Section 115TD: How Inadvertent Non-Compliance Converts Exemption into Tax Liability

May 14, 2026 519 Views 0 comment Print

The article explains how procedural lapses in trust registration renewal can activate Section 115TD and impose heavy tax on accreted income. Even inadvertent non-compliance may create severe financial consequences.

Interplay of Section 45(5A) (JDAs) with RERA & Capital Gains Timing Issues

May 14, 2026 732 Views 0 comment Print

The article explains how Section 45(5A) shifted the capital gains trigger for landowners from JDA execution to issuance of the completion certificate. It also examines the impact of RERA-regulated project timelines.

Virtual Digital Assets (VDAs) Taxation: Decoding Compliance Maze

May 14, 2026 480 Views 0 comment Print

The article explains the taxation framework for cryptocurrencies, NFTs, and other VDAs under Sections 115BBH and 194S. It highlights the harsh restrictions on deductions and loss set-off.

“Guarantee Fee” Puzzle – Is it “Interest” or “Fees for Technical Services”?

May 14, 2026 159 Views 0 comment Print

The article explains how the High Court held that corporate guarantee fees do not qualify as Fees for Technical Services under the India-UK DTAA. The ruling emphasizes the absence of technical knowledge or consultancy services.

India’s Evolving PE and Business Connection Tests – Post-Digital Economy BEPS Changes

May 14, 2026 156 Views 0 comment Print

The article explains how India has broadened Permanent Establishment and Business Connection concepts after BEPS reforms. It highlights the shift from physical presence to economic nexus-based taxation.

Equalisation Levy Sunset? Evaluating Policy Shifts Beyond August 2024

May 14, 2026 150 Views 0 comment Print

The article analyses why India may continue its Equalisation Levy regime beyond August 2024 due to delays in the OECD/G20 Pillar One framework. It discusses the impact on digital businesses and global tax relations.

Abandoned Software Development Costs Allowed as Revenue Expense in Adadyn Technologies Case

May 14, 2026 108 Views 0 comment Print

The article explains how the ITAT allowed deduction of abandoned software project costs as revenue expenditure. The ruling clarifies that no capital asset arises when a project is permanently abandoned.

Dividend from Foreign Subsidiaries: Taxation & Section 80M Interplay

May 14, 2026 207 Views 0 comment Print

The article explains how Section 80M applies only to domestic dividends, leaving foreign subsidiary dividends fully taxable in India. This creates economic double taxation for Indian parent companies.

Interest on Broken Periods for Banks – Revisiting SC’s 2024 Ruling (Bank of Rajasthan)

May 14, 2026 159 Views 0 comment Print

The article explains the Supreme Court’s landmark 2024 ruling that broken period interest on debt securities is capital in nature. The judgment rejects the Revenue’s attempt to tax such receipts as interest income.

Diminishing Role of “Tax Planning” in New Concessional Regimes – Is Optimization Now Dead?

May 14, 2026 141 Views 0 comment Print

The article explains how Sections 115BAA, 115BAB, 115BAC, and 115BAE have reduced the importance of traditional deduction-based tax planning. It highlights the shift toward strategic and substance-driven tax optimization.

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