Taxbuzz | Royalty paid on inter-company sales not at Arm’s Length

Payment of royalty on the sales made to the associated enterprise has always been disputed by the Indian Transfer Pricing department as not satisfying the arm’s length test. In a recent ruling[1], the Hon’ble Delhi Bench of Tribunal was pleased to delete the transfer pricing adjustment made in respect of payment of royalty on invoices […]

TaxBuzz | Section 153C: Limitation, Computation and Satisfaction

We are pleased to share with you a copy of our in-house publication – “TaxBuzz… Vaish in Courtroom”, wherein we have analysed the recent ruling of the Delhi High Court in a batch of matters titled Ojjus Medicare Pvt Ltd. The High Court in the said ruling, has delved into aspects relating to determination of […]

Presentation of Seminar on Analysis of Union Budget 2023

The Union Budget, 2023 has been presented in the backdrop of a volatile geopolitical and economic environment. However, the Budget does a good balancing act, staying course to meet the target to cut down on the fiscal deficit and at the same time focusing on the increased capital outlay to bolster growth. From the Direct-tax […]

“Solely” means ‘Only’ – Supreme Court on Scope of Exemption u/s 10(23C)

We are pleased to share with you a copy of our in-house publication – “TaxBuzz…”, wherein we have analysed the recent ruling of the Supreme Court in a batch of matters titled New Noble Education Society. The Supreme Court in the said ruling, has delved into aspects relating to registration of ‘education institutions’ under section […]

TaxBuzz | NCLT overrules applicability of GAAR in case of Panasonic Merger!

Recently, the Chandigarh Bench of National Company Law Tribunal (“NCLT”)  approving the amalgamation of a loss-making company, Panasonic India Private Limited (Transferor Company) with the profit-making company, Panasonic Life Solutions India Private Limited (Transferee Company), overruled the objections raised by the Income tax Department qua the proposed merger on the ground that the proposed merger was […]

TaxBuzz | Demystifying the decision of Supreme Court on reassessment notices

The Hon’ble Supreme Court has on 04.05.2022 pronounced much awaited decision in the case of Union of India v. Ashish Agarwal: C. A. No. 3005/2022. The said decision of the Hon’ble Supreme Court will give rise to numerous issues and litigation will not be put to rest. In this Tax Buzz, we have analyzed, repercussion […]