TMI Short Notes

TMI Short Notes on various issues

51. Invalid Notices and the Importance of Proper Jurisdiction: Lessons from a High-Profile Tax Case

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52. Upholding Precedent: Supreme Court's Stance on Taxation of Cross-Border Software Payments (Royalty)

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53. The Cross-Border Software Purchase Conundrum: Supreme Court's Clarification on TDS for Non-Resident Software Transactions as Royalty

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54. Navigating Tax Exemptions u/s 80P: The Supreme Court's Verdict on Cooperative Societies vs. Banks

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55. Principles of Natural Justice in Tax Litigation: Unraveling the Significance of Cross-Examination Rights in Tax Cases

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56. Deadline Extension for Processing E-Filed Tax Returns: Refund Claims on Income Tax Returns

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57. Modes of filing of ITR: Amendments to Rule 12 of the Income Tax Rules 1962

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58. Navigating Legal Timelines: The Impact of Incomplete ITBA Orders on Appeal Limitations.

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59. Navigating the Thin Line Between Charity and Commerce: Amendment of Trust Deed and Compliance with Section 13(1)(c)

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60. Changing Objectives of Registered Societies: Exemption u/s 11 and survival of the Registration u/s 12A r.w.s 12AA

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61. Judicial Scrutiny of Residential Status and Jurisdictional Shift in Income Tax Cases

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62. Scrutinizing the Genuineness of Gifts in Income Tax Law: Taxability of Gift u/s 68

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63. Interpreting TDS Liability u/s 194-I against Lease Payments: A Legal Analysis of Security Deposit vs. Rent for Tax Purposes

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64. Evaluating Jurisdictional Validity in Taxation: The Significance of Draft Assessment Orders under Section 144C

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65. Breaking Down the Supreme Court's Decision on Double Taxation Avoidance Agreements

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66. Balancing Sovereignty and Law: India's Treaty-Making Powers and Domestic Enforcement

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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95. 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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96. 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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97. Non-Delegability of Discretionary Powers in Income Tax Assessments: Administrative Discretion in Special Tax Audit Procedures u/s 142

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

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

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

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