TMI Short Notes

TMI Short Notes on various issues

51. Special Taxation of Non-Resident Sportsmen and Entertainers : Clause 211 of the Income Tax Bill, 2025 Vs. section 115BBA of the Income-tax Act, 1961

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52. Special Tax Regimes for Gaming and Gambling Incomes : Clause 194 (Table: S. No. 1) of Income Tax Bill, 2025 Vs. Section 115BB of Income Tax Act, 1961

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53. Special concessional tax regime for new manufacturing co-operative societies in India : Clause 204 of the Income Tax Bill, 2025 Vs. Section 115BAE of the Income Tax Act, 1961

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54. Concessional tax regime for resident cooperative societies in India : Clause 203 of the Income Tax Bill, 2025 Vs. Section 115BAD of the Income Tax Act, 1961

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55. Introducing a new tax regime with revised tax slabs and by eliminating various exemptions and deductions : Clause 202 of Income Tax Bill, 2025 Vs. Section 115BAC of the income tax Act, 1961

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56. Concessional tax regime for new manufacturing domestic companies : Clause 201 of the Income Tax Bill, 2025 Vs. Section 115BAB of the income tax Act, 1961

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57. Optional Concessional Taxation for domestic Companies : Clause 200 of the Income Tax Bill, 2025 Vs. Section 115BAA of the Income-tax Act, 1961

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58. Concessional Taxation for Manufacturing Domestic Companies : Clause 199 of Income Tax Bill, 2025 Vs. Section 115BA of Income-tax Act, 1961

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59. Taxation of Special Incomes in India "Profits and gains from Life Insurance Business" : Clause 194 of the Income Tax Bill, 2025 Vs. Section 115B of the Income-tax Act, 1961

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60. Evolving the Taxation of Foreign Portfolio Investment : Clause 210 of the Income Tax Bill, 2025 Vs. Section 115AD of the Income Tax Act, 1961

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61. Taxation of income from Global Depository Receipts (GDRs) earned by resident employees of Indian companies or their subsidiaries engaged in specified knowledge-based industries or services : Clause 193 of the Income Tax Bill, 2025 vs. Section 115ACA of the Income Tax Act, 1961

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62. Legislative framework governing the taxation of income derived by non-residents from bonds and Global Depository Receipt : Clause 209 of Income Tax Bill, 2025 Vs. Section 115AC of the Income-tax Act, 1961

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63. Evolution of Special Tax Regimes for Offshore Funds : Clause 208 of the Income Tax Bill, 2025 Vs. Section 115AB of the Income-tax Act, 1961

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64. Tax treatment of the accumulated balance of recognised provident funds (RPFs) : Clause 191 of the Income Tax Bill, 2025 Vs. Section 111 of the Income-tax Act, 1961

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65. Streamline, simplify, and update the tax framework applicable to non-residents and foreign companies : Clause 207 of the Income Tax Bill, 2025 Vs. Section 115A of the Income-tax Act, 1961

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66. Special procedure for calculating tax liability on income discovered during search operations : Clause 192 of the Income Tax Bill, 2025 Vs. Section 113 of the Income-tax Act, 1961

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67. Recalibrating Long-Term Capital Gains Taxation : Clause 198 of the Income Tax Bill, 2025 Vs. Section 112A of the Income Tax Act, 1961

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68. Reforming Long-Term Capital Gains Taxation : Clause 197 of the Income Tax Bill, 2025 Vs. Section 112 of the Income-tax Act, 1961

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69. taxation of short-term capital gains (STCG) : Clause 196 of the Income Tax Bill, 2025 Vs. Section 111A of the Income-tax Act, 1961

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70. Determination of tax liability which no tax is payable under the provisions of the Act : Clause 190 of the Income Tax Bill, 2025 Vs. Section 110 of the Income-tax Act, 1961

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71. Definition for the operation of the General Anti-Avoidance Rule (GAAR) : Clause 184 of Income Tax Bill, 2025 Vs. Section 102 of Income-tax Act, 1961

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72. Legislative tool curbing aggressive tax planning and abusive tax avoidance Scheme : Clause 183 of the Income Tax Bill, 2025 Vs. Section 101 of the Income-tax Act, 1961

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73. Procedural Safeguards and the Scope of GAAR : Clause 183 of Income Tax Bill, 2025 Vs. Section 100 of Income-tax Act, 1961

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74. Curbing aggressive tax avoidance strategies : Clause 182 of the Income Tax Bill, 2025 Vs. Section 99 of the Income-tax Act, 1961

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75. Continuation and refinement of the General Anti-Avoidance Rule : Clause 181 of the Income Tax Bill, 2025 Vs. Section 98 of the Income-tax Act, 1961

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76. Statutory backbone of India's General Anti-Avoidance Rule (GAAR) : 180 of the Income Tax Bill, 2025 Vs. Section 97 of the Income-tax Act, 1961

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77. "Curbing aggressive tax avoidance strategies" under the General Anti-Avoidance Rule (GAAR) : Clause 179 of the Income Tax Bill, 2025 Vs. Section 96 of the Income-tax Act, 1961

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78. Countering the tax avoidance through codification of the General Anti-Avoidance Rule (GAAR) : Clause 178 of the Income Tax bill, 2025 Vs. Section 95 of the Income Tax Act, 1961

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79. limitation on Debt interest deduction as expenses in cross-border transactions : Clause 177 of Income Tax Bill, 2025 Vs. Section 94B of Income-tax Act, 1961

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80. Comprehensive framework for dealing with transactions with any notified jurisdictional areas : Clause 176 of the Income Tax Bill, 2025 Vs. Section 94A of the Income Tax Act, 1961

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81. Anti-Avoidance Provisions in Securities Transactions : Clause 175 of the Income Tax Bill, 2025 Vs. Section 94 of the Income-tax Act, 1961

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82. Designed provisions to counteract tax avoidance schemes involving cross-border transactions : Clause 174 of the Income Tax Bill, 2025 Vs. Section 93 of the Income-tax Act, 1961

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83. Important Definition within the framework of transfer pricing and anti-avoidance measures : Clause 173 of Income Tax Bill, 2025 Vs. Section 92F of Income-tax Act, 1961

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84. Statutory Reporting & Penalties for persons entering into international and specified domestic transactions : Clause 172 of the Income Tax Bill, 2025 Vs. Section 92E of the Income-tax Act, 1961

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85. Revamped framework of the Transfer Pricing documentation & Penalties : Clause 171 of the Income Tax Bill, 2025 Vs. Section 92D of the Income-tax Act, 1961

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86. Harmonizing India's Secondary Adjustment Regime in Transfer Pricing : Clause 170 of the Income Tax Bill, 2025 Vs. Section 92CE of the Income-tax Act, 1961

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87. Streamlining APA Implementation and Transfer Pricing Compliance : Clause 169 of Income Tax Bill, 2025 and Section 92CD of Income-tax Act, 1961

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88. Enhancing Certainty and Compliance in Transfer Pricing through Advance Pricing Agreements : Clause 168 of the Income Tax Bill, 2025 Vs. Section 92CC of the Income-tax Act, 1961

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89. Special provisions concerning the avoidance of tax, specifically empowering to Board to make "safe harbour" rules : Clause 167 of the Income Tax Bill, 2025 Vs. Section 92CB of the Income-tax Act, 1961

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90. Role of the Transfer Pricing Officer in Ensuring Arm’s Length Compliance : Clause 166 of the Income Tax Bill, 2025 Vs. Section 92CA of the Income-tax Act, 1961

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91. Reframing Arm's Length Pricing in India's Evolving Transfer Pricing Regime : Clause 165 of the Income Tax Bill, 2025 Vs. Section 92C of the Income-tax Act, 1961

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92. Meaning of Specified Domestic Transactions under Clause 164 of Income Tax Bill, 2025 Vs. Section 92BA of Income-tax Act, 1961

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93. Meaning of International Transaction : Clause 163 of the Income Tax Bill, 2025 Vs. Section 92B of the Income-tax Act, 1961

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94. Remuneration and interest received by an individual partner from a partnership firm can be subjected to the presumptive taxation Under Section 44AD?

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95. Meaning of Associates Enterprise under Clause 162 of the Income Tax Bill, 2025 Vs. Section 92A of the Income-tax Act, 1961

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96. Computation of income arising from international transactions and specified domestic transactions : Clause 161 of the Income Tax Bill, 2025 vs. Section 92 of the Income-tax Act, 1961

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97. Future of Unilateral Agreement relief in India : Clause 160 of the Income Tax Bill, 2025 Vs. Section 91 of the Income-tax Act, 1961

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98. Streamlining Double Taxation Relief and International Tax Agreements : Clause 159 of Income Tax Bill, 2025 Vs. Section 90A of Income Tax Act, 1961

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99. Comprehensive Reform in International Taxation and Treaty Implementation : Clause 159 of Income Tax Bill, 2025 Vs. Section 90 of Income-tax Act, 1961

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100. Addressing Cross-Border Taxation of Foreign Retirement Benefits : Clause 158 of Income Tax Bill, 2025 Vs. Section 89A of Income Tax Act, 1961

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