Month: December 2015

Permanent Establishment: The Continuing Conundrum

CA Ashish Karundia has conducted a meticulous study into the weaknesses and failures of the traditional concept of a permanent establishment. He argues, with reference to a multitude of domestic and international judgements, that the PE concept has failed in reaching the objective of legitimate taxation of income that is attributable to an enterprise of the non-resident enterprise

Deduction Of Interest On Loan A Part Of Which Is Given To Sister/ Subsidiary Concern Without Interest

Shri. Akhilesh Kumar Sah, Advocate, has provided valuable perspective on the controversial issue relating to the deduction of interest on loan diverted to sister/ subsidiary concerns without interest. The entire law on the subject as encapsulated in the recent verdict of the Supreme Court in Hero Cycles (P) Ltd vs. CIT is considered

Whether Compact Disc, Tape Recorded Conversation Is A Document And Admissible As An Evidence

Shri. Akhilesh Kumar Sah, Advocate, has explained the law on whether compact disc, tape recorded conversation is a “document” and admissible as an evidence in the light of the verdict of the Super Court in Shamsher Singh Verma vs. State of Haryana and other important judgements

Digest Of Important Judgements On Transfer Pricing, International Tax And Domestic Tax (Aug to Oct 2015)

Shri. Sunil Moti Lala, Advocate, has prepared a compilation of important judgements on transfer pricing, international tax and domestic tax reported in the period from August to October 2015. The author has meticulously and systematically classified the judgements into various categories to enable ease of reference. A pdf copy of the digest is available for download. The digest will prove invaluable to all practitioners of taxation law

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