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Ca Sohil Rana

Latest Posts by Ca Sohil Rana

Ruling on Benefit of India–Mauritius Treaty on Capital Gains (POEM/PPT/GAAR)

June 19, 2020 2751 Views 0 comment Print

AAR – Ruling on Benefit of India–Mauritius Treaty on Capital Gains taken by Tiger Global International Group in respect of Shares of Flipkart (Singapore Co) sold by Mauritius based Co to a Company in Luxembourg (which is controlled by Walmart) and the value of shares is derived from assets located in India Summary of Case […]

Vivad se Vishwas (No Dispute but Trust) Scheme

February 6, 2020 5793 Views 3 comments Print

Under Vivad se Vishwas scheme taxpayers are only required to pay amount of disputed taxes and they will get immunity from interest, penalty and prosecution if he pays disputed taxes before 31st March 2020. Those who avail this scheme after 31st March 2020 need to pay extra 10 percent of disputed taxes. This scheme will remain operational till 30th June 2020; however, this date may also be extended by few months (probably up to Sep – Dec 2020).

Snapshots of Union Budget 2020 – Direct Tax Amendments

February 2, 2020 13629 Views 0 comment Print

Budget 2020- Article explains New Tax Regime (Optional Scheme) Vs Earlier Regime (Existing Scheme) – For Individual and HUF, Exemptions and Deductions Foregone to opt for optional Scheme, Insertion of Section 194O : TDS on Sale of Goods and Services through E-Commerce, Amendment in Section 206C (TCS Provisions), Modification of Residency Provisions (Sec – 6 […]

Fee for Technical Services: Detailed Analysis

April 6, 2019 180306 Views 7 comments Print

In some treaties there is make available clause in Article 12/13  which mandates that services should “make available” technical knowledge, experience, skill, know how or processes. The term make available has far reaching significance since it limits scope of FTS. This clause is generally available in tax treaties with developed countries which want to retain the exclusive rights for taxing the transaction where there is no transfer or dissemination of knowledge or skill involved.

Bogus Share Premium/Share Capital – Responsibility of Assessee to Prove with Cognet Evidence

March 19, 2019 3702 Views 0 comment Print

Merely because assessee company had filed all primary evidence, it could not be said that onus on assessee to establish credit worthiness of investor companies stood discharged u/s 68 of the Income Tax Act, 1961.

TDS on Sale of Property in India – Simplified

October 29, 2018 23514 Views 6 comments Print

In case of Sale of Property by Residents IN case of sale of immovable property by the residents in India buyer is required to deduct tax @ 1% u/s 194 IA of Income Tax Act, 1961 on sale consideration if value of property exceeds Rs. 50 Lacs. TDS shall also be deducted in case of […]

“Here I Come” — TDS Provisions under GST (01.10.2018)

September 14, 2018 7521 Views 0 comment Print

The Central Government hereby, vide notification no. 50/2018 and 51/2018 — Central Tax, appoints the 1st day of October, 2018, as the date on which the provisions of section 51 and 52 of CGST Act (Provisions related to TDS and TCS) Shall come into force with respect to persons specified under respective sections. Tax Deducted […]

Section 14A (Read with Rule 8D) – Conundrum for Assessee’s

September 11, 2018 19572 Views 3 comments Print

The time for completion of Income Tax assessments for A.Y 2016-17 is coming and Sec- 14A is one of the reason of scrutiny assessment of assesse, therefore here I am discussing some topics relating to sec – 14A read with rule 8D to resolve issues.

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