TMI Short Notes

TMI Short Notes on various issues

21. Navigating DTAAs: A Comparative Analysis of India, Netherlands, France, and Switzerland

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22. The OECD Membership Puzzle: Interpreting 'Is' in Double Taxation Agreements

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23. The Dual Life of Treaties: Understanding Their Enforcement in Indian Law

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24. Assessment Proceedings and Validity of Section 143(2) Notices: Jurisdictional Clarity and Monetary Limit

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25. Unexplained Cash Deposits and Section 115BBE: Applicability of Higher Rate of Tax

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26. Section 127 of the Income Tax Act: A Case Study on Jurisdictional Transfer

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27. Interpreting Sections 22, 23, and 24: Taxation of Notional Rental Income from House Property and Vacancy Allowance

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28. Section 153A and Income Tax Assessments Post Search and Seizure Operations: Exploring the Role of Incriminating Material in Legal Adjudication

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29. Analysis of Judicial Approach in Tax Evasion through Accommodation Entries: A Case Study

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30. The Taxation of Cooperative Societies: A Legal Analysis of Deduction Eligibility U/s 80P

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31. Analyzing Section 43B's Application in Service Tax Liabilities: A Legal Perspective.

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32. Assessing the Enforceability of Section 148 Notices Post-Assessee's Demise: Legal Heirs and Income Tax Proceedings

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33. Analyzing the Threshold for Criminal Prosecution in Cases of Non-Compliance with Income Tax Laws

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34. Timeliness and Validity of Charitable Trust Registrations under Section 80G: A Legal Examination

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35. Navigating the Nuances of Income Tax Reassessment Post-Finance Act 2021: Resetting the Clock in Tax Reassessments

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36. The Source Rule in International Taxation: Tax Implications for Non-Resident Service Providers

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37. Taxation of 'Success Fees' in International Transactions: The Nexus Doctrine: Situs of residence and Situs of source of income

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38. TDS and International Transactions: Categorization of Payments under the ambit of "royalty" or "fees for included services (FTS)"

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39. Assessment u/s 153C and Unexplained Investments: A Case Study in Legal Reasoning

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40. Delhi High Court Elucidates on the Scope of Section 80IA in the Context of Business Expansion: Interpretation of 'Undertaking'

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41. Penalty Limitations and Reasonable Cause: Navigating the Nuances of Tax Penalties

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42. Income Tax Return Delays: High Court Rules on Tax Authority's Decision-Making Boundaries

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43. The Interplay of Sales and Bogus Purchases in Tax Evasion Cases: Assessing Tax Evasion Allegations

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44. Proportionality and Evidence in Tax Assessments: Accommodation entries, Bogus Purchase and Estimation of Gross Profit (Income)

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45. Judicial Scrutiny of Tax Deducted at Source (TDS) Non-Deposit: Protecting the Rights of Taxpayers Against Employers' Failure to Deposit TDS

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46. Dynamics of Tax Exemption Registrations: A Comprehensive Analysis of ITAT Ahmedabad’s Decision on Section 80G Application Rejection

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47. Transfer Pricing Litigation: The Evolving Landscape of Arm's Length Price Determination in India

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48. Revisiting the Scope of Revisionary Powers U/s 263: Assessing the Adequacy of Assessment Procedures in Taxation Disputes

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49. Maintaining the Sanctity of Search and Seizure Procedures: Emphasizing the rigorous compliance with procedural requirements to uphold the legitimacy of search and seizure operations

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50. Analyzing the Tax Implications of Cross-Border Payments: Recognizing the payments as either 'Royalty' or 'Fee for Included Services' u/s 9(1)(vii)

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51. Non-Delegability of Discretionary Powers in Income Tax Assessments: Administrative Discretion in Special Tax Audit Procedures u/s 142

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52. Taxation of Domain Registration Services in Godaddy.Com LLC Case: Tax Implications for Digital Services

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53. Navigating the Complexities of Section 80P Deductions for Cooperative Societies

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54. Navigating Pecuniary Jurisdiction in Tax Assessments: Assessment Orders and Legal Jurisdiction

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55. "Sales Tax Subsidy and Its Classification in Income Tax: Revenue or Capital receipt

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56. Trust Registration and Tax Exemptions in India: rejection of registration u/s 12AB for want of supporting evidences

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57. Condonation of Delay in Taxation in filing applications for registration u/s 12A/12AA:

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58. Navigating Procedural Timelines in Tax Exemption Applications

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59. Mandatory Draft Assessment Orders for Foreign Entities and Section 144C Compliance: A Legal Perspective

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60. The Impact of PAN Mismatch in Corporate Tax Filings and Resolving Name Discrepancies in Tax Documents: Legal Implications and Remedies

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61. Analyzing the Dispute Over Section 14A Disallowance and Interest under Section 244A in Income Tax Appeals

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62. Condonation of Delay in Tax Refund: Analyzing the Right to Interest

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63. Balancing Corporate Operations and Tax Obligations: High Court's Interim Order on Share Buyback Taxation

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64. Section 80P and Cooperative Societies: Unraveling the Tribunal's Interpretation

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65. Supreme Court Upholds High Court's Decision on Tax Evasion Case: An Analysis

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66. Reassessing Accommodation Entries: Insights from a High Court Judgment

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67. A Judicial Perspective on Section 148A of the Income Tax Act: Amended Reassessment Provisions

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68. Threshold set for monetary limits in filing appeals by Revenue: A policy shift towards reducing litigation and financial burden on the judiciary and taxpayers

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69. High Court's Stance on Penalty Notices in Tax Law: A Balance Between Procedure and Justice

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70. Decoding the Penalty Provisions under Section 271(1)(c): Analyzing the Fine Line Between Concealment and Inaccuracy in Taxation

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