🌐 CIT (IT) vs. Infosys Ltd. – Karnataka High Court on Section 206AA vs. DTAA Rates for TDS on Royalty/FTS (2024) 📌 Background Tax deduction at source (TDS) provisions for payments made to non-residents often raise significant interpretational issues—especially where domestic law mandates a certain withholding rate, but the applicable Double Taxation Avoidance Agreement (DTAA) […]
🏦 CIT (IT) v. HSBC Bank (Mauritius) Ltd – Bombay High Court on Exemption of Interest Income under India–Mauritius DTAA (2024) 📘 Background The taxation of interest income under Section 9(1)(v) of the Income-tax Act, 1961, often leads to disputes in cross-border banking transactions, especially where Double Taxation Avoidance Agreements (DTAAs) provide preferential treatment to […]
🌾 Nataraj Ramaiah vs. ITO – ITAT Chennai on Sale of Agricultural Land Beyond Municipal Limits (2024) 📌 Background The taxation of capital gains arising from the sale of agricultural land under Section 2(14)(iii) of the Income-tax Act, 1961 has been a recurring issue, particularly in cases where urban expansion blurs the distinction between rural […]
Avtar Singh v. ITO (2024) 230 TTJ 506 239 DTR 113 🏡 Avtar Singh vs. ITO – ITAT Chandigarh on Sale of Agricultural Land Beyond Municipal Limits (2024) 📌 Background The classification of agricultural land as a capital asset under Section 2(14)(iii) of the Income-tax Act, 1961 has always been a contentious issue. The key […]
🧾 LGW Industries Ltd. vs. Union of India (2022) – Calcutta High Court on ITC Denial Due to Non-Existent Suppliers 📌 Background The judgment in LGW Industries Ltd. vs. Union of India [(2022) 134 Taxmann.com 42 (Calcutta High Court)] deals with a recurring and critical issue under the GST regime — denial of Input Tax […]
PAN and TAN Explained (2025): The Permanent Account Number (PAN) and Tax Deduction and Collection Account Number (TAN) are vital identifiers under the Income-tax Act, 1961, enabling smooth tax administration in India.This comprehensive guide explains their meaning, purpose, structure, application process, online verification, and compliance tips — essential for every taxpayer, business, and professional. 1. […]
In the interconnected global economy, Base Erosion and Profit Shifting (BEPS) has emerged as a critical challenge to tax fairness and fiscal integrity.BEPS Explained: It refers to tax planning strategies that exploit gaps and mismatches between tax systems to shift profits to low or no-tax jurisdictions, thereby eroding the tax base of higher-tax economies. To […]
