Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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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