Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
The India-Sri Lanka tax treaty is amended to expressly prevent non-taxation or reduced taxation arising from tax evasion, avoidance and treaty-shopping arrangements that indirectly benefit third-State residents. It also introduces a principal purpose test: treaty benefits may be denied where, considering all relevant facts and circumstances, obtaining the benefit was one of the principal purposes of an arrangement or transaction, unless granting it accords with the object and purpose of the relevant treaty provisions. The Protocol entered into force on 19 June 2026 and applies in India to income derived in fiscal years beginning on or after 1 April 2027.
The India-Sri Lanka tax treaty is amended to expressly prevent non-taxation or reduced taxation arising from tax evasion, avoidance and treaty-shopping arrangements that indirectly benefit third-State residents. It also introduces a principal purpose test: treaty benefits may be denied where, considering all relevant facts and circumstances, obtaining the benefit was one of the principal purposes of an arrangement or transaction, unless granting it accords with the object and purpose of the relevant treaty provisions. The Protocol entered into force on 19 June 2026 and applies in India to income derived in fiscal years beginning on or after 1 April 2027.
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