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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
The Income Tax Bill 2025 consolidates and modernizes deemed income provisions previously contained in Sections 7 and 8 of ITA 1961. The new Clause 7 creates a unified framework dividing deemed income into two sub-clauses: employee benefits and dividend income. Key modifications include updated references to Schedule XI for provident funds, expanded scope of employer contributions, and refined dividend income treatment. The consolidation maintains essential provisions while improving organizational clarity through precise terminology and streamlined cross-references. The restructuring aims to reduce interpretational disputes and align with contemporary business practices, though initial implementation may require updated judicial precedents. The reform represents a systematic enhancement of deemed income provisions while preserving their fundamental characteristics.
The Income Tax Bill 2025 consolidates and modernizes deemed income provisions previously contained in Sections 7 and 8 of ITA 1961. The new Clause 7 creates a unified framework dividing deemed income into two sub-clauses: employee benefits and dividend income. Key modifications include updated references to Schedule XI for provident funds, expanded scope of employer contributions, and refined dividend income treatment. The consolidation maintains essential provisions while improving organizational clarity through precise terminology and streamlined cross-references. The restructuring aims to reduce interpretational disputes and align with contemporary business practices, though initial implementation may require updated judicial precedents. The reform represents a systematic enhancement of deemed income provisions while preserving their fundamental characteristics.
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