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 All Industries+2
Direct Tax Amicus: October 2016
Stock Appreciation Rights, also known as SARs are a novel way of rewarding the employees of an organisation by granting them the right to benefit from any appreciation in the value of the common stock (shares) of a corporation.
Read More 08 Dec 2016
Direct Tax All Industries+2
Direct Tax Amicus: December 2016
The similarity between customs valuation and transfer pricing methodologies is that the objective of both is to establish whether or not the price at which the transaction has been entered into has been influenced by the relationship between the parties entering into the transaction.
Read More 01 Dec 2016
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Direct Tax Amicus: November 2016
A company is a juristic personality which not only comes into existence by operation of law but its cessation also takes place by operation of law.
Read More 01 Nov 2016
Direct Tax All Industries+2
Direct Tax Amicus: September 2016
While the requirement of compliance with transfer pricing regulations by all the AEs involved in a transaction has been a subject matter of intense debate and practically, many foreign AEs do not comply with TP regulations in India, a recent ruling of a Special Bench of ITAT, Kolkata emphasises the requirement of compliance with Indian TP regulations by non-residents even where they do not receive any income because of their relationship with Indian AE.
Read More 01 Sept 2016
Direct Tax All Industries+2
Direct Tax Amicus: August 2016
Delhi High Court in a recent decision has held that the deduction under Section 80-IA(2A) for telecommunication companies is also available with respect to various ancillary income such as liquidated damages, interest, sale of directories and extra-ordinary items of income.
Read More 01 Aug 2016
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Direct Tax Amicus: July 2016
Recently, the Central Board of Direct Taxes notified the rules for granting of Foreign Tax Credit (FTC) to resident taxpayers on income earned in foreign jurisdiction.
Read More 01 Jul 2016
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Direct Tax Amicus: April 2016
Last year, the Indian Government introduced a voluntary declaration of undisclosed foreign income and assets for resident taxpayers under the Black Money Act which met with limited success.
Read More 04 Jun 2016
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Direct Tax Amicus: June 2016
While Section 9(1) (ii) creates a deeming fiction on what could be an accrual or deemed accrual in respect of salary received/receivable by a non- resident, there is no clear explanation in the Act with respect to amounts/income which has been received or deemed to have been received.
Read More 01 Jun 2016
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Direct Tax Amicus: March 2016
With the Finance Bill 2016, the penalty regime in income-tax law is proposed to undergo a major overhaul.
Read More 05 May 2016
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Direct Tax Amicus: May 2016
India entered into The Double Taxation Avoidance Agreement (‘DTAA’) with Mauritius on 24th August, 1982.
Read More 01 May 2016
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Direct Tax Amicus: February 2016
With the developed economies feeling the brunt of losing tax revenues due to tax planning, provisions relating to Transfer Pricing were introduced to ensure economic value add in every jurisdiction is adequately compensated.
Read More 05 Apr 2016
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Direct Tax Amicus: January 2016
CBDT recently notified a draft of guiding principles for determination of PoEM of a company. PoEM has been defined to be a place where key management and commercial decisions that are necessary for the conduct of the business of an entity as a whole are, in substance, made.
Read More 03 Apr 2016