Income Tax : The Finance Minister has introduced the Union Budget 2022 (‘Budget’) in the Parliament aiming to boost economic growth and rev...
Income Tax : The issue before the Hon’ble Supreme Court (SC) was whether section 14A of the Income-tax Act, 1961 (the Act) enables the Depart...
Income Tax : The Finance Ministry vide Circular no. 17/2021 dated 09 September, 2021 announced extensions to the deadline for the filing of the...
Income Tax : The Finance Minister has introduced the Union Budget 2021 (‘Budget’) in the Parliament amidst the panic and upheaval caused to...
Income Tax : With the COVID-19 pandemic playing havoc and resulting in many practical challenges, the Indian Government has come out with vario...
Income Tax : In the case of Khoday Distilleries Ltd. The SC has explained the judicial effect of the dismissal of a Special Leave Petition, fil...
Income Tax : Hon’ble Bombay High Court (HC) held that the transfer pricing officer (TPO) cannot suo-motu assume jurisdiction to determine the...
Income Tax : Samsung Electronics Co. Ltd. Vs. DCIT (Int. Taxation)- ITAT Delhi Analysis of the Samsung Case on the Determination of a Permanent...
Income Tax : AAR has held that digital and other connected equipments can, depending on the business model, determine the formation of a perman...
Income Tax : Supreme Court Ruling – The Guidance Note issued by Institute of Chartered Accountants of India on lease rental income which help...
Income Tax : The CBDT has issued Notification No. 25 of 2020 dated 20 May 2020, wherein it has notified the year of applicability of the ‘...
Income Tax : The Circular has extended the due date to 30 April 2019, for furnishing Country-by-Country Reports (CbCRs), in respect of reportin...
Management service charges paid to AE by the assessee, which is closely linked to core business activities of the assessee, benchmarked by applying TNMM at entity level is held to be appropriate. Need and benefit from intra-group management services demonstrated by the assessee upheld – [McCann Erickson India Pvt. Ltd. v. ADCIT (ITA No. 5871/D/2011)]
This is a unique Ruling rendered by the AAR wherein the concept of PE of a group of companies has been discussed. It is well known that a subsidiary of a foreign company is not enough to qualify the former as a PE of later or its group companies. The mere existence of a company control is not, in fact, enough, in accordance with Article 5 of the OECD Model, However, considering the peculiar facts of the case, in this ruling the AAR has observed that 100% subsidiary is created for the purpose of attending to the business of the Group in India and therefore, such Indian subsidiary must be taken to be a PE of the Group in India.
Deduction in respect of payment of Life Insurance Premium [section 80C] Deduction for life insurance premium as regards insurance policies issued on or after 1 April 2012 shall be available only if premium payable does not exceed 10% of actual capital sum assured. (reduced from 20 %)
Vodafone International Holdings B.V. (VIHB), a Dutch based Vodafone entity, acquired a controlling stake in Hutchison Essar Limited [(HEL), now known as Vodafone Essar Limited VEL)], an Indian company, from Cayman Islands based Hutchison Telecommunications International Limited (HTIL) by acquiring shares of CGP Investment (CGP), a Cayman Islands company [which belonged to (HTIL)] in February 2007. CGP held various Mauritian companies, which in turn held a majority stake in HEL.
