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.
The Supreme Court’s ruling on Permanent Establishment (PE) expands taxability for MNEs, holding that “effective control and continuous direction” through operational continuity, even without a traditional fixed office, constitutes a fixed-place PE under Article 5.
Recent ITAT and High Court rulings confirm the Tax Residency Certificate (TRC) is key to claiming DTAA benefits, reinforcing protection for pre-2017 foreign investments against ‘shell company’ allegations.
Indian statutory auditors must embrace IT proficiency and CAATs to manage ERP data and system controls. Non-IT friendly audits risk incomplete evidence, fraud, and reputational damage.
GST rulings clarify ITC eligibility on high-tension electricity infrastructure installed outside factory premises. Movable nature and business use prevent blockage under Section 17(5).
Understand key provisions of advance tax under the Income Tax Act — who is liable, due dates, revision of estimates, payment procedure, capital gains treatment, TDS credit, Form 28A requirements, and computation rules.
Know about Statement of Financial Transaction (SFT) or Reportable Account under Section 285BA — entities liable to file, reportable transactions, due dates, penalties, and compliance procedures.
Know about TAN under Section 203A of the Income Tax Act—its purpose, applicability, application process, forms, penalties, and key rules for TDS/TCS deductors and collectors in India.
Understand the provisions of tax audit under Section 44AB of the Income Tax Act, including its objectives, applicability, prescribed forms, due dates, and penalties for non-compliance by businesses and professionals.
Victimology focuses on victim rights and rehabilitation under CrPC/BNSS and NALSA. It leverages AI and digital platforms for support, compensation (CVCF), and restorative justice.
