This article in this issue of Direct Tax Amicus seeks to analyze the applicability of the non-discrimination article in tax treaties on disallowance of expenses on payment made to non-residents without withholding...

The article in this issue of Direct Tax Amicus discusses a recent ruling of the Delhi Appellate Tribunal in the case of Prism Scan Express Private Limited.

The article in this issue of Direct Tax Amicus discusses the issue of attribution of profits in case of losses at the global level, which has once again gathered spotlight as the Delhi High...

The article in this issue of Direct Tax Amicus examines as to whether in case of fresh issuance or allotment of shares, be it Equity Shares or Preference Shares, Section 56(2)(x) of the Income Tax...

The Supreme Court recently passed a judgment, in favour of the Revenue department, interpreting the Most Favoured Nation (‘MFN’) clause present in various Double Taxation Avoidance Agreements (‘DTAAs’).

The article in this issue of Direct Tax Amicus discusses the adverse impact, under the Income Tax Act, 1961, of conversion of outstanding loan to equity.

The article in this issue of Direct Tax Amicus seeks to examine the question as to whether treaty benefits should at all be provided if the non-resident seller of shares does not have much commercial substance.

The Bombay High Court has recently held that the timelines for passing an assessment order specified in Section 153 of the Income Tax Act, 1961 are not to be extended in cases where the assessee takes the Dispute Resolution Panel route and the final assessment order under Section 144C(13) has to be passed

The Finance Act, 2021 substituted the provisions of reassessment under the Income-tax Act, 1961. Under the new reassessment provisions, the concept of ‘reason to believe’ has been substituted with ‘information’ which suggests that the income has escaped assessment.

The article in this issue of Direct Tax Amicus discusses a recent decision of the Supreme Court in the case of Saraf Exports v. CIT, wherein the Apex Court has held that export incentives like Duty Drawback and DEPB will not qualify as first-degree nexus for the purposes of claim of deduction under Section 80-IB of the Income Tax Act, 1961.