Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
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The India-Mauritius tax treaty Protocol replaces the treaty preamble to confirm that eliminating double taxation must not create opportunities for non-taxation or reduced taxation through tax evasion, avoidance, or treaty-shopping arrangements benefiting third-jurisdiction residents. It inserts an entitlement-to-benefits rule denying treaty relief where, considering all relevant facts and circumstances, obtaining the benefit was one of an arrangement's or transaction's principal purposes, unless granting relief accords with the relevant treaty provision's object and purpose. The Protocol entered into force on 10 August 2026 and applies from that date regardless of when tax is levied or the relevant taxable year.
The India-Mauritius tax treaty Protocol replaces the treaty preamble to confirm that eliminating double taxation must not create opportunities for non-taxation or reduced taxation through tax evasion, avoidance, or treaty-shopping arrangements benefiting third-jurisdiction residents. It inserts an entitlement-to-benefits rule denying treaty relief where, considering all relevant facts and circumstances, obtaining the benefit was one of an arrangement's or transaction's principal purposes, unless granting relief accords with the relevant treaty provision's object and purpose. The Protocol entered into force on 10 August 2026 and applies from that date regardless of when tax is levied or the relevant taxable year.
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