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OverviewThe introduction of the Goods and Services Tax (GST) in 2017 marked a significant overhaul of the indirect tax system in India, with a special focus on simplifying compliance for small busines...

IntroductionThe electronic waybill (e-way bill) framework, regulated under Rule 138 of the GST Rules, governs the movement of goods across India’s territories. Compliance requires timely digital submi...

Overview of Procedural Fairness in GST Amnesty SchemesThe introduction of amnesty schemes under the Goods and Services Tax (GST) framework is a crucial strategy for recovering government dues and reso...

Background and Case Overview(i) Context and Judicial ProverbThe time-honored legal maxims, "Justice delayed is justice denied" and "Justice should not only be done but should manifestly and undoubtedl...

IntroductionThe draft Income Tax Bill 2025 introduces several provisions and retains some from the earlier law, but overlooks key issues that could escalate compliance demands and result in increased...

Introduction and BackgroundBlue Star Limited secured a loan of Rs. 50,00,000 from its director, Mr. Timothy Edwin, without obtaining prior approval from the Audit Committee as mandated under Section 1...

Overview of High Sea Sales TransactionsHigh Sea Sales refer to instances where an original importer transfers ownership of goods to another buyer while those goods are still in transit—after being dis...

Introduction: Faceless Assessment and Section 148 – Key ConcernsThe implementation of the faceless assessment mechanism under the Income-tax Act, 1961, has introduced significant procedural requiremen...

IntroductionRecently, a state GST authority dispatched approximately 6,000 demand notices to traders, citing analyses of their UPI transaction data. The authorities claimed that these traders exceeded...

Background and OverviewDeductors and collectors frequently encounter automatic interest charges under Section 201(1A)(ii) or Section 206C(7) of the Income-tax Act, 1961, even when they have made timel...

Rise in Refund-Related Cyber Frauds During ITR SeasonThe period for filing Income Tax Returns (ITR) is currently at its peak. Many assessees who have already submitted their returns are anticipating r...

1. OverviewThe Supreme Court of India, in its recent Hyatt International Southwest Asia Ltd. decision ([2025] 176 taxmann.com 783 (SC)), delivered significant clarity on the concept of "fixed place of...

1. IntroductionThe Income Tax Department’s latest utility for Tax Audit Reports has introduced much-needed clarity on reporting obligations under Clause 22 of Form 3CD, especially with regards to paym...

Introduction: The Core Issue Before the Supreme Courti) The Central QuestionThe Supreme Court in the case of HYATT INTERNATIONAL SOUTHWEST ASIA LTD. v. Addl. DIT ([2025] 176 taxmann.com 783 (SC)) was...

Overview and ContextThe real estate industry in India is subject to various complexities, particularly from a regulatory and indirect tax perspective. The treatment of Joint Development Agreements (JD...

Introduction to E-commerce Operations under GST(i) Definition of Electronic Commerce Operator (ECO)According to Section 2(44) of the Central Goods and Services Tax (CGST) Act, 2017, an Electronic Comm...

Background: Unintended GSTR-3A Notices to Cancelled Composition Assessees(i) Recent DevelopmentsRecently, a significant number of assessees registered under the GST composition scheme, who had previou...

Background and Case Overview(i) Factual Matrix(a) In the case of PCIT vs. TE Connectivity India Pvt. Ltd., the Karnataka High Court ruled in favor of the Revenue, upholding the Principal Commissioner...

1. OverviewSections 68 to 69C of the Income-tax Act, 1961 have emerged as powerful legal mechanisms for assessing officers, frequently utilized to tax unexplained credits, assets, investments, and exp...

Introduction to Upfront Lease Premiums in BOT Leases(i) Understanding the Structure of Upfront Lease Premiums(a) In Build-Operate-Transfer (BOT) lease agreements, it is common for the lessee to make a...