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DRP in Transfer Pricing Assessment: Appellate Rights and Lessons from Vodafone
1. INTRODUCTION: THE DUAL-ROUTE ASSESSMENT MECHANISM The Unique Feature of Transfer Pricing Assessment Unlike ordinary income tax assessments, transfer pricing assessments have a m
Section 115JB MAT vs Section 14A Rule 8D: Why Accounting Standards Prevail Over Tax Formulas
1. INTRODUCTION: THE CONCEPTUAL CLASH The Fundamental Tension At the heart of the Section 14A Rule 8D vs. Section 115JB debate lies a profound conceptual clash: On one side: The
Explanation 1 to Section 115JB – A Clause-By-Clause Analysis Of Book Profit Adjustments
1. INTRODUCTION: THE ARCHITECTURE OF BOOK PROFIT What is Explanation 1? Explanation 1 to Section 115JB(2) is the rulebook for computing book profit. It specifies, with surgical pre
Minimum Alternate Tax (MAT) Demystified – Book Profit vs. Taxable Income Explained
1. INTRODUCTION: THE TWIN TAX PROBLEM The Scenario That Started It All Imagine it’s the year 1997. You’re a wealthy Indian businessman running a successful manufacturin
Section 14A in MAT (Section 115JB): Can Rule 8d Disallowances Inflate Book Profits?
1. The Core Contradiction: Section 14A vs Section 115JB MAT The Core Contradiction Imagine this scenario: Company ABC Ltd. for AY 2023-24: Under Section 14A (Normal Computat
The Suo Moto Disallowance Trap – When Your Own Return Becomes Evidence Against You
1. INTRODUCTION: THE SELF-INCRIMINATION PARADOX The Core Tension There’s a peculiar paradox in Indian tax law: the more transparent and self-critical you are in your tax retu
Section 14A Disallowance – Understanding The Fundamental Principle And Rule 8D Computation
1. INTRODUCTION & CONTEXT Why This Matters For any business investing in tax-exempt securities (dividend-yielding shares, mutual funds generating exempt income, Section 10 inve
Block Assessment and Search Assessment: Complete Legal Guide with Procedures, Case Law & Checklists
Evolution, Statutory Comparison, Procedural Safeguards, and Practical Guidance for Tax Professionals Executive Summary: Two Regimes, One Principle India’s approach to taxing
The Satisfaction Note Doctrine in Income Tax Search Assessments: From Calcutta Knitwears to Jasjit Singh
A Comprehensive Legal Analysis of Procedural Safeguards, Judicial Safeguards, and Practical Implementation Under the Income Tax Act, 1961 Executive Summary: Key Takeaways on the Sa
X v. State of Rajasthan and Tapas Kumar v. State of Chhattisgarh: A Comprehensive Analysis of Bail in Serious Offences
Introduction The Supreme Court of India, through its benches led by Justice J.B. Pardiwala and Justice R. Mahadevan, has issued two landmark judgments that fundamentally reshape th
