"Ex-Global Head of Tax (SVP) - Lupin Group, Senior global tax professional with 40+ years of progressive experience, including 26 years as Senior Vice President and Global Head of Tax at Lupin Group (transnational pharmaceutical organization with revenues exceeding US$ 3 Bn). Brings deep expertise across international taxation, cross-border structuring, M&A tax, transfer pricing, IP and R&D taxation, and complex tax litigation. Led and argued many tax matters before CIT(A) and ITAT and assisted in matters before ITAT and High Courts. Recognized for architecting resilient global tax structures, resolving high-stakes disputes, optimizing MAT/SEZ/patent income regimes, and advising boards, promoters and senior leadership. "
Capital gains liability for non-individual taxpayers under an unregistered Joint Development Agreement (JDA) arises immediately upon execution and granting enjoyment rights (AY 2020-21), based on Section 2(47)(vi) of the Income Tax Act, despite construction delays.
Section 251 grants CIT(A) co-terminus powers with the AO to confirm, reduce, or enhance assessment. However, Supreme Court rulings restrict the CIT(A)’s power to enhance by introducing a new source of income not considered by the AO in the original assessment.
PPT provisions inapplicable in absence of separate notification incorporating MLI provisions into India-Ireland tax treaty Background The Mumbai ITAT in Sky High Appeal XLIII Leasing Company Limited v. ACIT (2025) 177 taxmann.com 579 (Mum)/ TS-1085–ITAT-2025(Mum) and the Delhi ITAT in Kosi Aviation Leasing Ltd. v. ACIT [ITA No. 994/Del/2025, dated 30-9-2025] have held that operating […]
Supreme Court rulings in Wipro and Shriram Investments mandate strict adherence to return filing deadlines: fresh claims/withdrawals of exemptions (like Sec 10B) via revised returns filed after the original due date are invalid. Appellate authorities retain power to admit new claims.
ITAT Mumbai ruled that gains from rights entitlement transfers are exempt under Article 13(6) of the India-Ireland DTAA because they are distinct from shares, not covered by Article 13(5). The Tribunal also affirmed that short-term capital losses from STT-paid shares can be set off against short-term capital gains from non-STT-paid shares.
