Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
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The Income Tax Bill 2025 establishes comprehensive criteria for income deemed to accrue or arise in India, focusing on four primary categories: income from Indian assets/sources, property, business connections, and capital asset transfers. The legislation introduces significant provisions for digital economy taxation through the Significant Economic Presence (SEP) concept, while maintaining traditional nexus rules. Key elements include expanded definitions of royalties encompassing digital rights, technical service fees excluding construction projects, and refined business connection tests. The framework incorporates substantial value derivation tests for indirect transfers, with specific exemptions for portfolio investors and small shareholders. This modernized approach aligns with OECD BEPS recommendations while preserving India's sovereign taxation rights, particularly in digital commerce and cross-border transactions.
The Income Tax Bill 2025 establishes comprehensive criteria for income deemed to accrue or arise in India, focusing on four primary categories: income from Indian assets/sources, property, business connections, and capital asset transfers. The legislation introduces significant provisions for digital economy taxation through the Significant Economic Presence (SEP) concept, while maintaining traditional nexus rules. Key elements include expanded definitions of royalties encompassing digital rights, technical service fees excluding construction projects, and refined business connection tests. The framework incorporates substantial value derivation tests for indirect transfers, with specific exemptions for portfolio investors and small shareholders. This modernized approach aligns with OECD BEPS recommendations while preserving India's sovereign taxation rights, particularly in digital commerce and cross-border transactions.
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