Delhi High Court recently over turned an order of Authority of Advance Rulings (‘AAR’) 1 which denied private equity firm Tiger Global tax exemption under the India...

Indian Angel Tax Provisions have bemused many since the incorporation of Section 56(2)(viib) in Income Tax Act and just when we thought that the jurisprudence on Angel Tax was maturing and Government would rethink to whittle down...

During Covid, online gaming as an industry experienced meteoric growth, gaining popularity among the new-age GenZ and millennials. Online games were easily accessible through smartphones, play stations, Nintendo, and Xbox and were...

UAE has introduced a federal decree-law on Corporate Tax that is going to be implemented from June 2023 after which all UAE businesses will need to comply with Transfer Pricing rules and documentation requirements...

Chennai ITAT (“ITAT” or “Tribunal”) held impairment loss as non-operating in nature in its recent ruling in the case of M/s. DIAB Core Materials Pvt. Ltd. V DCIT1. The impairment...

On December 18, 2020 the Organization for Economic Cooperation  and Development (OECD) released its guidance  on the transfer pricing implication COVID -19 pandemic  (hereinafter, the “Guidance”) .

Directorate  of Revenue Intelligence (‘DRI’) is the apex intelligence and investigative agency for matters relating to violation of the Customs Act. However, when it comes to administration of Customs Regulations there  are limits to the agency’s powers  as recently held  by Supreme Court..

The levy of Extra duty deposit (“EDD”) in case of Related Party Imports has been been a bone of contention under  Customs  Regulations. Fundamentally Fundamentally Fundamentally Fundamentally EDD is a security deposit levied during pendency of investigation by Special  Valuation Branch (SVB).

Retrospective taxation of indirect transfer of Indian assets has been a subject matter of protracted protracted litigation between MNEs and the Indian Tax Authorities. In 2012, provisions of the Indian Tax Code were amended to clarify...

OECD under the BEPS Action Plan discussed several options to tackle the direct tax arising in digital businesses. One such option was a new nexus rule based on “significant economic presence”.

UAE introduced federal decree law on corporate tax, called the Federal Corporation Tax (‘ on 9 th December, 2022 In the previous three editions of....

The Central Board of Direct Taxes vide notification dated 22nd May 2023, issued guidelines providing clarification in respect of the calculation and the manner for tax deduction pertaining to online gaming (“Guidelines”). Additionally, Rule 133 has been introduced as part of the...

In the first edition of UAE Transfer Pricing (‘TP’) bulletin we had provided a comparative overview of the salient features of UAE and Indian TP regulations. In this edition, we dive further into some key aspects of TP provisions...

Prima facie a dichotomy exists in the objective of the Revenue and Customs department while the latter seeks to raise the value of a transaction between related parties to...

We are pleased to bring to you the monthly round-up of significant rulings under Indirect Tax/GST regime. The month of March-April saw some significant rulings coming from High Court and Authority for Advance Rulings. The important rulings are summarized...

On December 18 ,2020 the Organization for Economic Cooperation  and Development (OECD) released its guidance on the transfer pricing implications of COVID-19 pandemic.

Recently  Delhi  High Court in the case of Concentrix Services  Netherlands  BV v.ITO ITO(TDS) had the opportunity to interpret the Most Favoured Nation("MFN") clause in the protocol to India-Netherlands tax treaty.

Recently, the Central Board of Indirect  Taxes and Customs  through  an Administrative  Circular (Circular No. 14 /2021-Customs dated July 7, 2021) improvised  the procedure for Faceless Assessment rolled out on PAN India basis with effect from September 4, 2020.

There has been a widespread agreement for some time that the international tax system needs reform to address the  digitalisation of the global economy. Under the current international tax rules, multinational enterprises (“MNEs”)...

India-Mauritius tax treaty has come under scanner yet again with a recent pronouncement by the Authority for Advance Rulings (“AAR”) in the case of Tiger Global International II Holdings, In re  [1].

UAE introduced federal decree-law on corporate tax, called the Federal Corporation Tax (‘CT’) on 9th December, 2022. In the previous editions of UAE Transfer Pricing (‘TP’) bulletin we had provided...

The Explanatory Guide provides an explanation of the meaning and intended effect of each Article of the UAE CT. It may be used in interpreting the corporate tax law and must be read in conjunction with the UAE...

Finance Bill 2023 proposes to reduce time available for furnishing Transfer Pricing Report from 30 days to 10 days allowed earlier (from date of request by Transfer Pricing Officer). Additional time up...

The Mumbai Tribunal (“Tribunal”) in its recent ruling in DCIT v. Credit Suisse (Singapore) Ltd1. ruled that offshore
commission income earned...

The Central Government has extended the timelines for various compliance requirements under the Income Tax Act . CBDT recently issued a circular; Circular  No .01 / 2022 (dt. 11th January, 2022) providing relaxation in respect of several compliances.

The Central Government has extended timelines for various compliance requirements under the Income Tax Act. CBDT recently issued  a circular; Circular  No .17/2021 (dt. 9th September, 2021)  providing relaxation in respect of several  compliances.

The Central Government has extended timelines for various compliance requirements under the Income Tax Act. CBDT issued  two circulars; Circular No. 9/2021 (dt. 20th May, 2021) and Circular No .12 /2021 (dt.25 th June, 2021) providing relaxation in respect several compliances.

Recently, the Central  Board of Indirect Taxes and Customs through an Administrative Circular (Circular No .14 /2021 - Customs  dated July 7, 2021) improvised the procedure procedure procedure for Faceless Assessment rolled out on PAN India basis with effect from September 4,2020.

The Finance Act 2016 introduced provisions relating to Country by Report (CbCR) and Master File pursuant to adoption of OECD’s EPS Action Plan-13 in India. While the law was enacted and it was made applicable with effect from 1st April 2017 (i.e. from AY 2017-18 onwards), the notification regarding the Final Rules was on 31 st October 2017 providing much awaited guidelines with respect to maintenance and furnishing of Master File and CbCR.

The Indian judiciary is devising novel ways for presiding over urgent matters in the wake of the corona virus exigency. While a near-country wide lockdown has brought the economy to a screeching halt, courts and tribunals across the country, including the Apex Court are taking measures to deal with urgent matters.