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: September 2023
The article in this issue of Direct Tax Amicus seeks to examine the question as to whether treaty benefits should at all be provided if the non-resident seller of shares does not have much commercial substance.
Read More 07 Dec 2023
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Direct Tax Amicus: December 2023
The article in this issue of Direct Tax Amicus examines as to whether in case of fresh issuance or allotment of shares, be it Equity Shares or Preference Shares, Section 56(2)(x) of the Income Tax...
Read More 01 Dec 2023
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Direct Tax Amicus: November 2023
The Supreme Court recently passed a judgment, in favour of the Revenue department, interpreting the Most Favoured Nation (‘MFN’) clause present in various Double Taxation Avoidance Agreements (‘DTAAs’).
Read More 01 Nov 2023
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Direct Tax Amicus: August 2023
The Bombay High Court has recently held that the timelines for passing an assessment order specified in Section 153 of the Income Tax Act, 1961 are not to be extended in cases where the assessee takes the Dispute Resolution Panel route and the final assessment order under Section 144C(13) has to be passed
Read More 23 Oct 2023
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Direct Tax Amicus: October 2023
The article in this issue of Direct Tax Amicus discusses the adverse impact, under the Income Tax Act, 1961, of conversion of outstanding loan to equity.
Read More 01 Oct 2023
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Direct Tax Amicus: July 2023
The Finance Act, 2021 substituted the provisions of reassessment under the Income-tax Act, 1961. Under the new reassessment provisions, the concept of ‘reason to believe’ has been substituted with ‘information’ which suggests that the income has escaped assessment.
Read More 12 Sept 2023
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Direct Tax Amicus: June 2023
The article in this issue of Direct Tax Amicus discusses a recent decision of the Supreme Court in the case of Saraf Exports v. CIT, wherein the Apex Court has held that export incentives like Duty Drawback and DEPB will not qualify as first-degree nexus for the purposes of claim of deduction under Section 80-IB of the Income Tax Act, 1961.
Read More 07 Aug 2023
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Direct Tax Amicus: May 2023
The article in this issue of Direct Tax Amicus discusses elaborately the recent amendment in Section 11 of the Income Tax Act, 1961 vide Finance Act, 2023, with effect from 1 April 2024. Noting that a charitable entity was allowed to accumulate a maximum of 15% of its income...
Read More 10 Jul 2023
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Direct Tax Amicus: April 2023
The article in this issue of Direct Tax Amicus discusses the labyrinth of exemption available to charitable institutes under the Income Tax Act, 1961. Considering the changing landscape of the exemption regime, right from Finance...
Read More 30 May 2023
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Direct Tax Amicus: March 2023
Amongst various tax amendment proposals announced this year, proposal for taxing ‘cash’ benefits and perquisites is likely to have a wide-reaching impact on the taxpayers, especially in Amongst various tax amendment proposals announced this year, proposal for taxing ‘cash’ benefits and perquisites is likely to have a wide-reaching impact on the taxpayers, especially in...
Read More 03 May 2023
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Direct Tax Amicus: February 2023
Income derived from Trust property has been exempt under Income-tax laws since the Act of 1886. Tracing the legislative history in respect of income from property held under trust, the author examines amendments made by Finance Act, 1970;
Read More 13 Apr 2023
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Direct Tax Amicus: January 2023
It gives me great pleasure to address you through this 100th issue of Direct Tax Amicus. I have always believed that the wealth of knowledge should be shared.
Read More 24 Mar 2023