"A qualified Chartered Accountant and Advocate specializing in the field of Direct Tax Litigation, International Taxation and Transfer Pricing and Benami Proeprty Law. Experienced professional in handling assessments and appeals matters under the Income Tax."
High Court held that IBC law overrides Income Tax law. The assessment proceedings initiated by the Income Tax Department for the assessment year which is covered by the date of resolution plan approved by the NCLT is not permissible as per IBC and hence, notices issued during the said period are liable to quashed.
As per Investopedia, a cryptocurrency is a digital or virtual currency that is secured by cryptography, which makes it nearly impossible to counterfeit or double-spend. A defining feature of cryptocurrencies is that they are generally not issued by any central governmental authority and thus immune to government interference or manipulation.
In 2012, after the adversarial decision of Supreme Court decision in the case of Vodafone, Indian Government had introduced slew of retrospective amendments in the Income Tax Act. This led to severe criticism from the International community and investors and damaged India’s image as investment hub. It further augmented litigation and huge taxes were blocked.
In ongoing commercial transactions amongst multinational group like sale, purchase or transfer of goods/services/assets etc., there arises receivable or payable from one group company to another. This is generally referred to as ‘Overdue Balance’.
Deeming provisions are important part of statutes in general and Income Tax Act (‘Act’) in particular. Without deeming provisions modern tax legislation cannot think of implementing effective tax administration. Considering the recent trend, one gets amused how much legislature has got creative in imagining tax fictions to collect revenue and plug loopholes;
There are situations where due to technical non compliance or due to procedural aspects credit TDS is denied to assesssee despite he is having Form 16A issued by deductor in support of his claim. However, CPC or even AO denies credit of such TDS and restricts claim to TDS as per Form 26AS only.
