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Startup Losses and Section 79 of the Income Tax Act, 1961: When Anti-Abuse Rules Kill Legitimate Restructuring
Introduction India’s startup ecosystem has grown into one of the most dynamic in the world, yet founders and investors continue to grapple with a tax provision that was never
Income Tax Treatment of Carbon Credits: Asset, Income, or Capital Receipt Under the IT Act, 1961?
Introduction Carbon credits — formally known as Certified Emission Reductions (CERs) — have occupied an increasingly contentious space in Indian tax jurisprudence over the past
Section 80M Inter-Corporate Dividend Deduction: The Cascading Tax Problem the Finance Act 2020 Left Unresolved
Introduction When the Finance Act 2020 abolished the Dividend Distribution Tax (DDT) under Section 115-O of the Income Tax Act, 1961, India shifted from a company-level tax to the
TDS on Salary for Remote Employees Across Multiple Indian States Under Section 192: Compliance Challenges”
Introduction The rise of remote work in post-pandemic India has created a TDS on salary compliance challenge that neither the Income Tax Act, 1961 nor the CBDT has clearly addresse
ESOP Taxation After Exit: Why Perquisite Tax at Exercise and Capital Gains at Sale Creates Double Taxation by Stealth
Introduction Employee Stock Option Plans (ESOPs) are among the most powerful instruments that Indian startups and companies use to attract, retain, and motivate talent. ESOPs give
Crypto Losses Under Section 115BBH: Why the No-Set-Off Rule Creates an Unconstitutional Tax on Notional Gains
Introduction When the Finance Act, 2022 introduced Section 115BBH into the Income Tax Act, 1961, it created one of the most structurally aggressive tax provisions that India’
Fractional Ownership of Real Estate and Income Tax: How Co-Ownership Platforms Fall Through the Cracks of Section 54 and 54F
Introduction Fractional ownership of real estate has moved from a niche arrangement between family members and business partners to a fully commercialised, technology-enabled inves
Section 56(2)(viib) Angel Tax Abolition 2024: Retrospective Refund Rights of Startups Assessed Between 2012–2024
The Twelve-Year Burden: What Was Angel Tax? When Finance Minister Pranab Mukherjee introduced the Finance Act, 2012, he inserted a clause into the Income Tax Act, 1961 that would g
ISD Mechanism Failure in GST: Why Shared Service Centres in Group Companies Can’t Use ISD Rules
Introduction The Input Service Distributor (ISD) mechanism under India’s Goods and Services Tax (GST) framework was conceived as a practical solution for large businesses tha
GST on Crypto-to-Crypto Swaps: Is It Barter Under Schedule I, or Does Section 7 Even Apply to Decentralized Exchanges?
Introduction The law relating to GST on cryptocurrency in India occupies a space that is simultaneously over-discussed and under-resolved. As decentralized finance (DeFi) expands,
