TMI Short Notes

TMI Short Notes on various issues

1. 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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2. 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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3. 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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4. 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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5. 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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6. 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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7. 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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8. 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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9. 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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10. 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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11. 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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12. 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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13. 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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14. 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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15. "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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16. 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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17. 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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18. 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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19. 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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20. 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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21. 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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22. 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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23. 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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24. 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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25. 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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26. 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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27. 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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28. 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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29. 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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30. 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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31. 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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32. 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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33. 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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34. 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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35. 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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36. 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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37. 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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38. 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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39. Continuity and Reform in Tax Relief for Irregular Income : Clause 157 of the Income Tax Bill, 2025 Vs. Section 89 of the Income Tax Act, 1961

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40. Constitutional Limits on GST: Principle of mutuality insulates transactions between clubs/associations and their members
    1 Comment

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41. Relief to resident individual taxpayers with lower and middle incomes by reducing their effective tax liability : Clause 156 of the Income Tax Bill, 2025 Vs Section 87A of the Income Tax Act, 1961

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42. The Structure and Implications of Income Tax Rebates : Clause 155 of the Income Tax Bill, 2025 Vs. Section 87 of the Income-tax Act, 1961.

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43. Analyzing the Tax Treatment of Collective Entities under Clause 310 of Income Tax Bill, 2025 Vs. Section 86 of Income-tax Act, 1961

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44. Tax Deductions for Persons with Disabilities : Clause 154 of the Income Tax Bill, 2025 vs. Section 80U of the Income Tax Act, 1961

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45. Statutory deduction for interest income derived from deposits : Clause 153 of the Income Tax Bill, 2025 Vs. Section 80TTA of the Income-tax Act, 1961

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46. Patent Royalty Deduction Scheme to Boost Innovation and R&D in India : Clause 152 of the Income Tax Bill, 2025 Vs. Section 80RRB of the Income-tax Act, 1961

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47. Incentivize and support authors by providing a tax deduction on royalty and copyright income : Clause 151 of the Income Tax Bill, 2025 Vs. Section 80QQA of the Income-tax Act, 1961

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48. Tax Incentives for Strengthening Agricultural Producer Companies : Clause 150 of Income Tax Bill, 2025 Vs. Section 80PA of the Income-tax Act, 1961

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49. A Contemporary Recasting of Section 80P for Strengthening the Co-operative Sector : Clause 149 of the Income Tax Bill, 2025 Vs. Section 80P of the Income-tax Act, 1961

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50. Preventing Double Taxation of Corporate Dividends : Clause 148 of the Income Tax Bill, 2025 Vs. Section 80M of the Income-tax Act, 1961

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