Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
The Income Tax Bill 2025 introduces substantial modifications to residential status provisions compared to the Income-tax Act 1961. Key changes include restructuring into 14 sub-sections, enhanced clarity in determining individual residency through refined 182-day and 60-day rules, and specific provisions for high-income individuals with Rs. 15 lakh threshold. The bill maintains dual criteria for company residency (Indian incorporation or POEM) while expanding POEM definition. NOR status criteria are broadened with additional categories for high-income individuals and deemed residents. The revised framework aligns with international standards, emphasizing substance over form and addressing global mobility concerns. These amendments aim to reduce interpretational disputes while providing clearer guidance for status determination across taxpayer categories.
The Income Tax Bill 2025 introduces substantial modifications to residential status provisions compared to the Income-tax Act 1961. Key changes include restructuring into 14 sub-sections, enhanced clarity in determining individual residency through refined 182-day and 60-day rules, and specific provisions for high-income individuals with Rs. 15 lakh threshold. The bill maintains dual criteria for company residency (Indian incorporation or POEM) while expanding POEM definition. NOR status criteria are broadened with additional categories for high-income individuals and deemed residents. The revised framework aligns with international standards, emphasizing substance over form and addressing global mobility concerns. These amendments aim to reduce interpretational disputes while providing clearer guidance for status determination across taxpayer categories.
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