Here is another episode of LKS’ all Law., where Mr. Devesh Aswal and Ms. Neha Jain discuss the topic “Cross-Border Share Sale – Eligibility for Tax Treaty Benefit”. The benefit under the tax treaty is subject to provisions of General Anti Avoidance Rules (GAAR) enacted under the domestic law and Principal purpose test (PPT) embedded in tax treaties. Under both GAAR and PPT, the benefit of tax treaties should be available only for transactions having commercial substance. Though both GAAR...
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Here is another episode of LKS’ all Law., where Mr. Devesh Aswal and Ms. Neha Jain discuss the topic “Cross-Border Share Sale – Eligibility for Tax Treaty Benefit”. The benefit under the tax treaty is subject to provisions of General Anti Avoidance Rules (GAAR) enacted under the domestic law and Principal purpose test (PPT) embedded in tax treaties. Under both GAAR and PPT, the benefit of tax treaties should be available only for transactions having commercial substance. Though both GAAR...
Change of opinion: Whether permissible under the new provisions of reassessment?
all Law.
10 minutes
2 years ago
Change of opinion: Whether permissible under the new provisions of reassessment?
The Finance Act, 2021 overhauled the then-existing reassessment provisions under the Income-tax Act. Earlier, the reassessment provisions required the Assessing Officer to form an “independent belief” based on the “new tangible material”. Now, the reassessment provisions have been made information centric. The Assessing Officer is required to possess the information that suggests that the income chargeable to tax has escaped assessment. For that matter, what constitutes information has also b...
all Law.
Here is another episode of LKS’ all Law., where Mr. Devesh Aswal and Ms. Neha Jain discuss the topic “Cross-Border Share Sale – Eligibility for Tax Treaty Benefit”. The benefit under the tax treaty is subject to provisions of General Anti Avoidance Rules (GAAR) enacted under the domestic law and Principal purpose test (PPT) embedded in tax treaties. Under both GAAR and PPT, the benefit of tax treaties should be available only for transactions having commercial substance. Though both GAAR...
