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Transactional net margin method- bridging theory and practice in transfer pricing
By Disha Deopura: This paper critically examines the complexities and limitations of the arm's length principle within transfer pricing frameworks, particularly focusing on its susceptibility to manipulation by multinational enterprises (MNEs) for tax advantage. By analyzing the application of the transactional net margin method and exploring the judicial reasoning in the Kellogg India case, the research highlights how… Read More ...
FOREIGN REMITTANCES & TCS PROVISIONS UNDER UNION BUDGET 2025
By FCS DEEPAK P. SINGH [Bsc.FCS, LLB, FIII, CiAFP]: Dear Friends, Hon’ble Finance Minister has presented excellent and people-oriented Budget-2025 on 1st February 2025. There are many expectations of the people from this Budget and PM as well as FM has assured earlier that they are going to gift various benefits to the people and the industry in this Budget-2025. The FM has herd… Read More ...
BUDGET 2025 ANALYSIS – DIRECT TAXES
By FCS DEEPAK P. SINGH [Bsc.FCS, LLB, FIII, CiAFP]: Dear Friends, Hon’ble Finance Minister, Mrs. Sitaraman has presented 8th Budget in a row and has become second Finance Minister after Shree Moraraji Desai , who had presented 10th Union Budgets on different time frames. Mr Desai had presented a total of 6 budgets during his tenure as finance minister from 1959 to 1964, and… Read More ...
Finance Bill Analysis 2025-By Vispi T. Patel, Chartered Accountant
By Vispi T. Patel Chartered Accountant: The Indian Budget for the fiscal year 2025-26 has been a subject of great anticipation and scrutiny, especially as the GDP is expected to grow by 6.4% as against the earlier estimates of around 7%. The budget was expected to lay down the path for increasing the GDP and increase employment. Guided by the objectives… Read More ...
BHATIA PROPCON. A JURISPRUDENTIAL FAILURE?
By ANADI VARMA: The article is a modest attempt to analyse the decision of Hon'ble Delhi HC on s 148 wherein, inspite of wrong section being invoked, the notice and order have been upheld under cl b and d of s 148A respectively.In the humble opinion of the author the decision fails the principles of natural justice as… Read More ...
A Landmark Ruling on Determination of Permanent Establishment due to secondment of employees
By Adv. Prateek Bhati: Case Brief of PCIT v. Samsung Electronics Co. Ltd in ITA 1029 of 2018 in Delhi High Court. Landmark Judgement which deals with determination of Permanent Establishment in India due to the activities of employees seconded by Parent Company to its Indian subsidiaries. Read More ...
An Overview of the Customs Act- Basic Concepts and Legal Perspectives
By Advocate Arjun Gupta, Bombay High Court: In this article, the key provisions alongwith a few Bombay High Court decisions are explained which will provide a better understanding or refreshed understanding of Customs law under the Customs Act, 1962. Read More ...
Emigrating Indians – Tax and Regulatory Considerations
By CA. Hardik Mehta & CA. Arwa Mahableshwarwala: Indian Migration - Overview India has been a key contributor to global migration. Indians migrate for a variety of reasons such as better work opportunities, family reunification, higher education, access to a better quality of life such as better health, education and infrastructure and obtaining citizenship. The most popular destinations for Indian migrants include USA,… Read More ...
Decoding Nri Taxation Landscape
By CA. Charmi Shah: Who is Non-Resident Indian? A Non-Resident Indian (NRI) is an individual of Indian origin who lives outside India for various reasons - personal, business, employment, education, etc. Read More ...
The Evolution of Bail Jurisprudence under the Prevention of Money Laundering Act, 2002 (PMLA)
By Aditya Ajgaonkar & Rupal Shrimal, Advocates: Introduction : The fame or the infamy of any criminal statute in our country seems to be a direct consequence of the difficulty in getting bail. The more elusive the order of bail, the more infamous the statute. The prosecution proceedings under the PMLA have created quite a buzz in the recent years. This is… Read More ...