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...
Impact analysis of the Supreme Court decision in Saraf Exports v. CIT: Worth the wager?
all Law.
7 minutes
2 years ago
Impact analysis of the Supreme Court decision in Saraf Exports v. CIT: Worth the wager?
The Hon’ble Supreme Court of India (“Hon’ble SC”) in the recent decision in Saraf Exports v. CIT settled the issue of entitlement of deduction as per Section 80IB of the Income Tax Act, 1961 (‘IT Act’). The issue was pertaining to the receipts under Duty Drawback scheme (‘DDS’) and transfer of Duty Entitlement Pass book scheme (‘DEPB’). During the subject period, the taxpayer received certain incentives under DDS and DEPB. These said benefits were claimed as deduction u/s Section 80IB of the ...
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...
