Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
The proposed amendments to income deemed to accrue or arise in India under the Income Tax Bill, 2025, introduce comprehensive modifications to existing provisions under ss 9 and 9A of ITA 1961. Key changes include expanded definition of business connection incorporating significant economic presence, detailed framework for digital economy taxation, and modified investment fund management provisions. The amendments align with OECD BEPS guidelines while introducing specific provisions for online advertising, data monetization, and digital services targeting Indian market. The revised framework modernizes India's international taxation approach, particularly addressing digital economy challenges. Notable implications include reassessment requirements for businesses' digital presence, enhanced scope of taxable income for non-residents, and modified compliance obligations for fund managers under the new regulatory structure.
The proposed amendments to income deemed to accrue or arise in India under the Income Tax Bill, 2025, introduce comprehensive modifications to existing provisions under ss 9 and 9A of ITA 1961. Key changes include expanded definition of business connection incorporating significant economic presence, detailed framework for digital economy taxation, and modified investment fund management provisions. The amendments align with OECD BEPS guidelines while introducing specific provisions for online advertising, data monetization, and digital services targeting Indian market. The revised framework modernizes India's international taxation approach, particularly addressing digital economy challenges. Notable implications include reassessment requirements for businesses' digital presence, enhanced scope of taxable income for non-residents, and modified compliance obligations for fund managers under the new regulatory structure.
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