The Delhi High Court has overturned reassessment proceedings against a Singaporean company owned by Blackstone Group holding a Tax Residency Certificate (TRC). The proceedings were initiated due to the claim that the company was not the beneficial owner of the share transactions, as the source of funds and its management was in the US. However, …
The case of Amarnath Aggarwal Builders (P) Ltd. v. DCIT deals with the issue of whether a business loss claimed by the assessee, a real estate developer, could be treated as a bad and doubtful debt by the tax authorities. The assessee had invested Rs. 1,10,00,000/- in the purchase of land and payment of fees …
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The assessee has filed an appeal against the order dated 18/03/2020 passed by the Ld. CIT(A)-3, Bangalore for the assessment year 2017-18. The grounds for appeal are as follows: Grounds of Appeal: Brief facts of the case are as under: The company in question is a private limited company operating in the software publishing, consultancy …
The appeal is filed by the assessee against the order dated 26.07.2021 passed by the Commissioner of Income-tax Appeals (CIT(A)) in a faceless appeal. The grounds of appeal are as follows: The appellant reserves the right to add, alter, rescind, or modify the grounds or present further documents, facts, or evidence before or during the …
Property sale by Non-Resident Indians (NRIs) and Overseas Citizen of India (OCIs) in India is a common transaction. In this regard, NRIs often seek various tax and legal services related to the sale of their property. One of the first services NRIs look for is obtaining a Lower TDS Certificate or Nil TDS deduction Certificate …
Tax planning, tax avoidance, and tax evasion are all related to the payment of taxes, but they represent different approaches and have distinct legal implications. Tax planning refers to the process of legally reducing the amount of tax that a person or company is required to pay. Tax avoidance refers to the legal use of …
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In the recent case of Brinda Rama Krishna v. ITO, the Bangalore Income Tax Appellate Tribunal (ITAT) allowed the assessee’s appeal and held that the requirement to furnish Form No. 67 was directory and that Rule 128 did not provide for the disallowance of foreign tax credit (FTC) on the non-furnishing of Form No. 67 …
Continue reading “Filing Form 67 is Not Mandatory for Claiming Foreign Tax Credit in ITR”
The use of tax havens has been a controversial topic for many years, with both supporters and critics of the practice having valid arguments. Tax havens are defined as countries or territories that offer low or no taxes on certain types of income or transactions, as well as strict financial privacy laws. These features make …
Continue reading “The Pros and Cons of Using a Tax Haven Countries”
Transfer pricing refers to the practice of setting prices for goods and services exchanged between related parties, such as subsidiaries of multinational companies. The purpose of transfer pricing is to ensure that the prices of these transactions are similar to those that would be charged by unrelated parties in comparable transactions, in order to prevent …
Continue reading “What is Transfer Pricing: Its Purpose and Various Methods”
The Bangalore Special Court for Economic Offenses has acquitted an individual from prosecution under Section 276CC for failure to file a return of income. The court accepted the individual’s claim that they had a bonafide belief that since tax on their salary was deducted by their employer and they had received a Form 16, they …
