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Overview of Limitation of Benefits (LoB) Clause in Double Taxation Avoidance Agreements
Overview of Limitation of Benefits (LoB) Clause in Double Taxation Avoidance AgreementsThe Limitation of Benefit (LoB) clause is designed to deter treaty abuse and ensure that the benefits of the agreement are exten...
Principle of the Peak Credit Theory in Income Tax
Principle of the Peak Credit Theory in Income TaxMeaning of Peak credit theory :§ Instead of taxing entire deposits, only the maximum unexplained balance (peak) is taxed§ Because wi...
Specific mechanism for Secondary Adjustments rules in Indian Transfer Pricing regime [Section 170 of the Income Tax Act, 2025
Specific mechanism for Secondary Adjustments rules in Indian Transfer Pricing regime [Section 170 of the Income Tax Act, 2025Section 170 of the Income Tax Act, 2025 provides that a secondary adjustment shall be made in c...
Capital gain exemption on transfer of long-term capital asset (other than residential house) [Section 54F of Income-tax Act, 1961]
Capital gain exemption on transfer of long-term capital asset (other than residential house) [Section 54F of Income-tax Act, 1961]Section 54F of Income-tax Act, 1961 grants exemption from long-term capital gains (LT...
Contribution from Foreign Countries [Under Foreign Contribution Regulation Act (FCRA), 2010]
Contribution from Foreign Countries [Under Foreign Contribution Regulation Act (FCRA), 2010]Any donation from a Non-resident Indian who is a foreign national can be received only if the recipient charitable trust or inst...
Tie breaker Rule in Double Taxation Avoidance Agreement (DTAA)
Tie breaker Rule in Double Taxation Avoidance Agreement (DTAA)The Tie breaker rule for residential status refers to the criteria used to determine an individual’s primary place of residence, usually for tax purpos...
Whether Sumptuary allowance granted to judicial officer is exempt from payment of Income Tax?
Whether Sumptuary allowance granted to judicial officer is exempt from payment of Income Tax?The sumptuary allowance is a specific benefit provided to judicial officers in India to cover entertainment expenses. This allo...
Analysis of judgement of Supreme Court delivered on 15.12.2025 in the case of Director of Income Tax, Mumbai v. M/s American Express Bank Ltd., on the issue of Deduction of head office expenditure in the case of non-residents under section 44C of the Income Tax Act, 1961
Analysis of judgement of Supreme Court delivered on 15.12.2025 in the case of Director of Income Tax, Mumbai v. M/s American Express Bank Ltd., on the issue of Deduction of head office expenditure in the case of non-resi...
Contribution from Foreign Countries [Under Foreign Contribution Regulation Act (FCRA), 2010]
Contribution from Foreign Countries [Under Foreign Contribution Regulation Act (FCRA), 2010]Any donation from a Non-resident Indian who is a foreign national can be received only if the recipient charitable trust or inst...
Assessment of Assessees in Entertainment Sector
Assessment of Assessees in Entertainment SectorEntertainment sector consists of different segments under its fold such as television, radio, music, event management, films, animation and visual effects, broadcasting, spo...