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Direct Tax Amicus: July 2024

The article in this issue of Direct Tax Amicus discusses Section 43B(h) of the Income Tax Act, 1961 which was introduced by Finance Act, 2023. Observing that despite the well-placed intent behind introducing the aforesaid provision,...

Direct Tax Amicus: June 2024

The Courts in the past have on numerous occasions held that the filing of statutory forms within the due date prescribed under the Income Tax Act, 1961, is a directory (and not mandatory) requirement, to claim deductions/exemptions that are available to taxpayers.

Direct Tax Amicus: May 2024

Section 281 of the Income Tax Act, 1961 empowers the Department to declare a transfer of an asset as void where the transferor, during the pendency of any proceedings under the IT Act or completion thereof...

Direct Tax Amicus: April 2024

The drastic difference in income-tax treatment of both the instruments – Life Insurance Policies and Annuities, requires closer examination of their meaning to distinguish one from another.

Direct Tax Amicus: March 2024

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...

Direct Tax Amicus: February 2024

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.

Direct Tax Amicus: January 2024

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...

Direct Tax Amicus: December 2023

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...

Direct Tax Amicus: November 2023

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’).

Direct Tax Amicus: October 2023

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.