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Supreme Court's Decision on Authority for Advance Rulings v. Tiger Global International: A Jurisdictional Perspective on Treaty Entitlement and Tax Avoidance
1. Background of the Dispute(i) The Parties and Their Structure(a) Tiger Global International II Holdings, III Holdings, and IV Holdings (collectively "TGM Mauritius") are private entities incorporate...
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The Crucial Role of Show Cause Notice in Income Tax Prosecution
1. Introduction: The Crucial Role of Show Cause Notice in Income Tax ProsecutionThe current legal regime under Section 491 (formerly Section 279) represents both the most onerous and most benevolent a...
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Union Budget 2026: Enhancing Certainty and Relief Measures for Individual Assessees
Overview: Anticipations and Context(i) Individual Assessees’ Expectations and Tax Relief ProspectsAs the announcement of the Union Budget 2026 nears, individual assessees are keenly awaiting the Finan...
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Union Budget 2026–27: Advancing Tax Certainty, Simplification, and Sustainable Growth
The upcoming Union Budget 2026–27 is anticipated to reinforce India’s economic trajectory by deepening structural reforms, maintaining fiscal discipline, and prioritizing productive capital outlays. T...
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Union Budget 2026: Key Reflections and Anticipated Changes in Direct Tax Laws
Overview: Budget as a Tool for Economic Assessment and Future PlanningEvery budget, whether at a household or national level, serves to evaluate current financial realities and chart a path toward tar...
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Section 124: The Criticality of Assessing Officer Jurisdiction – Raise Your Objection Early or Lose the Right
1. IntroductionImagine receiving an income tax notice, actively cooperating with the Income Tax Department, only to later realize that the Assessing Officer (AO) handling your assessment lacked the le...
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Draft Income Tax Rules 2026: A Comprehensive Analysis of India's Tax Overhaul
What has changed? Everything you need to know about the new compliance landscapeFebruary 2026 — In a move towards simplification and modernization, the Indian government has released the Draft Income...
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Revised Tax Regime for Buyback of Shares: Shift from Deemed Dividend to Capital Gains
Overview: Buyback of Shares versus Dividend DistributionIndian companies commonly use either share buyback or dividend distribution to return value to their shareholders. While dividend payouts are a...
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Union Budget 2026: Advancements for Global Capability Centers (GCCs) in India
IntroductionGlobal Capability Centers (GCCs) have emerged as pivotal players within India’s corporate ecosystem, facilitating operational efficiency, technological innovation, and international compet...
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Union Budget 2026: Overhauling the Penalty Regime—Towards Greater Clarity, Predictability, and Trust
Introduction: Embracing a New Era in Tax ComplianceThe presentation of the Union Budget 2026 by the Finance Minister marks a historic ninth consecutive budget, reflecting the aspirations and energy of...
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Comprehensive Overview: Evolution and Current Landscape of Buyback Taxation in India
Introduction(i) Evolution of Buyback Taxation in IndiaThe practice of companies repurchasing their own shares serves as a means to return accumulated profits or reserves to the shareholders. The tax i...
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A New Era of Tax Certainty for India's IT and GCC Sector
1. Introduction: A New Era of Tax Certainty for India's IT and GCC SectorThis year's Union Budget, crafted in the historic Kartavya Bhawan, marks a significant step in India's approach to tax administ...
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A Revamped Approach to Minimum Alternate Tax (MAT): Transitioning Indian Companies to the New Tax Paradigm
Introduction to MAT and Its Current StructureMinimum Alternate Tax (MAT) serves as an alternate tax computation method, compelling companies to pay tax on their book profits if such tax exceeds the li...
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Budget 2026: Five-Year Tax Exemption on Global Earnings for Foreign Specialists in India and In-depth Review of the Data Centre Tax Holiday
Five-Year Exemption on Global Income for Foreign Specialists in India(i) Policy Objective and Legislative FrameworkIn an ambitious step to transform India into a leading destination for advanced techn...
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Union Budget 2026: Key Direct Tax Proposals—Mixed Reactions from Assessees
The 2026 Union Budget presented by Finance Minister Mrs. Nirmala Sitaraman has left many assessees dissatisfied, as expectations for higher exemption thresholds and relaxed tax slabs were not fully ad...
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Union Budget 2026–27: Evaluating India’s Crypto Reporting Provisions under Sections 509 and 446
OverviewIndia’s Updated Approach to Crypto-Asset ReportingThe Union Budget 2026–27 has initiated a significant transformation in the Income-tax Act, 2025, by replacing the original penalty provisions...
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Budget 2026: Key Reforms to the NPO Regulatory Framework in the Income-tax Act, 2025
1. OverviewThe Income-tax Act, 2025 (ITA 2025) was designed to simplify and clarify tax laws. However, its initial effect on Non-Profit Organisations (NPOs) was to introduce interpretational ambiguiti...
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Significant Updates for Non-Resident Individuals (NRIs) and Foreign Investors: Budget 2026
OverviewThe Union Budget 2026 has introduced several provisions that are particularly relevant to non-resident individuals (NRIs) and foreign investors. These amendments are aimed at enhancing the inv...
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Significant Developments for Trusts and NGOs under the Income-tax Act, 2025
IntroductionThe regulatory landscape for trusts and non-profit organizations (NPOs) is experiencing significant transformation with the implementation of the Income-tax Act, 2025 (ITA 2025). With a de...
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Proposed Changes in Taxation of Share Buy-Backs: A Comprehensive Overview
Background and Contexti) Evolution of Taxation on Buy-Back of SharesTo fully appreciate the amendment proposed in the Finance Bill, 2026, regarding section 69 of the Income-tax Act, 2025, it is import...