Thursday 24 November 2022

Section 94B of the Income-tax Act, 1961 – Unanswered Questions.



Section 94B of the Act was introduced by the Finance Act, 2017 to give effect to 'OECD BEPS Action Plan 4 - Limiting Base Erosion Involving Interest Deductions and Other Financial Payments.

Transfer Pricing Master File Form 3CEAA – Practical considerations



Master File (MF) in Form3CEAA to be e-filed by Indian entities of MNE Group by the 
due date of filing IT return i.e., 30 November. While Part A of Form has no threshold, Part B to be filed when a) consolidated group revenue >Rs 500 cr & b) aggregate value of international transactions >Rs 50 cr, or aggregate value of IP transactions >Rs 10 cr.

Saturday 19 November 2022

ITC on residential dwelling occupied by the employee is allowed to the employer?



With the withdrawal of the GST exemption on the services by way of renting of residential dwelling for use as a residence when provided to a registered person (RP), an important question that arises is whether the RP is eligible to claim ITC of the GST applicable therein if the residential dwelling is occupied by his employees.

Monday 14 November 2022

UAE Corporate Tax wef. 01st June 2023

 

With effective from 01st June 2023, the new corporate tax will apply to businesses across all Emirates, with an exception for the extraction of natural resources, which will remain subject to Emirate level corporate taxation. Foreign entities and individuals will be subject to corporate tax only if they conduct a trade or business in the UAE in an ongoing or regular manner. It is important that businesses evaluate the impact of the introduction of UAE CT early on and proactively plan for a smooth implementation. 

Examples:

Friday 11 November 2022

What is GST Notice.

 Adjudication is adversarial, and Revenue is not willing to backdown from the 'view' canvassed merely because taxpayer has declined to subscribe to it. Revenue will want to exhaust every remedy available in law to 'save the demand'. Justifiably so.

What is Rule 132 of the Income Tax Rules?


 

1. Rule 132 is a beneficial clause allowing assessees to comply with the provision of Section 155 which allows Assessing Officers to re-compute the total income for such previous years in which the assessee would have claimed deduction of surcharge or cess subject to be disallowed u/s 40(a)(ii).

 

Taxation of Intangible assets acquired through business restructuring.

1.     Background    1.1        When a company aims to acquire another company's business through amalgamation or demerger, assets or ...