Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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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