Direct Tax Amicus

Direct Tax Amicus covers major changes in income tax laws. This newsletter contains an article on issue of topical interest or developing jurisprudence, notifications and circulars issued during the period and important decisions and judgments (under Ratio Decidendi) covering various facets of income tax law and procedures. It usually covers recent developments pertaining to classification of expenditure, application of transfer pricing (TP) provisions, issues around DTAAs, computation of income, exemptions, etc.

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Direct Tax Amicus: December 2015
Direct Tax Amicus for the month of December 2015 covers article titled ‘Situs of IP for taxing rights’. According to the author, States that want to extend their taxing power on IP holding companies should first have some understanding of the nature of IP rights.
Read More 01 Dec 2015
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Direct Tax Amicus: September 2015
Direct Tax Amicus of September 2015 issue covers an article pertaining the analysis of consortium model and how it has now gained popularity, whereby companies usually collaborate and jointly bid for government projects. Notification & Circular portion of Direct Tax Am
Read More 19 Nov 2015
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Direct Tax Amicus: August 2015
The August, 2015 issue of Direct Tax Amicus features an article titled ‘Jurisprudence of International Tax Law’. In this article the author discusses how the Inter-Nation Equity concept has played a pivotal role in the development of international tax law as it stands today. According to
Read More 12 Nov 2015
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Direct Tax Amicus: November 2015
Provisions relating to deduction of tax at source (‘TDS’) do offer the government a good tool of efficient tax recovery but unless counterbalanced with a measure like Section 197, can become a weapon of oppression.
Read More 01 Nov 2015
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Direct Tax Amicus: October 2015
Article in this October 2015 issue of Direct Tax Amicus titled “Month-end Provisions and Reversal – Is TDS called for?”
Read More 01 Oct 2015
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Direct Tax Amicus: July 2015
The July, 2015 issue of Direct Tax Amicus features an article on ‘Corporate Guarantee – Certainty in taxation not guaranteed!’. This article analyses tax implications of various transactions arising out of a contract of guarantee between Associated Enterprises (‘AEs&r
Read More 02 Sept 2015
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Direct Tax Amicus: June 2015
The June, 2015 issue of Direct Tax Amicus features an article on, International Taxation and Revenue Rule. In this article the author states that the concept of revenue rule in the nascent stage of international taxation contributed to the development of source and resident based taxation
Read More 27 Jul 2015
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Direct Tax Amicus: May 2015
The May, 2015 issue of Direct Tax Amicus features an article on applicability of res judicata in tax matters which discusses on certain key issues of non –applicability of doctrine of res judicata in taxation. The Circular and Instruction section covers a circular clarifying that no in
Read More 18 Jun 2015
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Direct Tax Amicus: April 2015
The April 2015 issue of Direct Tax Amicus features an article on compelling a non-resident to seek PAN which discusses two different decisions of the Tribunal with differing views on whether tax could be deducted at the rate prescribed in a treaty even when the non-resident does not have a P
Read More 01 Apr 2015
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Direct Tax Amicus: March 2015
The March 2015 issue of Direct Tax Amicus is devoted to highlights of changes in the Union Budget 2015 and includes the proposal to amend test of residence using Place of Effective Management (POEM) concept, deferral of GAAR by 2 years, abolition of wealth tax, clarity on allowance of bal
Read More 01 Mar 2015
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Direct Tax Amicus: February 2015
The article in the February 2015 issue of Direct Tax Amicus explores the controversy on allowability of depreciation in a finance lease transaction in the light of revised accounting standards to be notified by the Indian Government. The clarification issued by the Central Board of Direct
Read More 01 Feb 2015
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Direct Tax Amicus: January 2015
The issue of taxation of share holder activity which sans clarification by CBDT, is often subject of dispute forms the basis of discussion in the Article section of the January 2015 issue of Direct Tax Amicus. Central purchasing authority not being beneficial owner for purpose of DTAA, taxab
Read More 01 Jan 2015