Hello Team, We, as a family of 4, have accumulated sizeable amount (cash) that is supposed to be used for retirement purposes. The amount accumulated is through a sale of property (the tax for this transaction has been paid). Our goal is to form a private irrevocable specified trust, introduce the cash into trust while forming the trust and then deploy that cash into debt and equity investments. Following are our concerns: 1. Tax implication while introducing the cash into trust – It is very much clear that there won’t be any capital tax implication for introducing the cash into trust. BUT will there be any tax implication for the said transaction if the Settlor of the trust is one of the Beneficiaries?   2. Can there be a clause for the trustee that he/she could sell investments (debt/equity) on a regular basis and provide that to the beneficiaries on time to time basis to fund the beneficiaries retirement? 3. What would be the tax implication on the selling of equity/debt funds? Will the capital gain on the selling of equity be taxed as whole on the trust or the beneficiaries getting the fixed shares would be taxed in individual capacity? (like all of the 4 would pay capital gains tax on the proportionate amount that they receive from the trust?)

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I am a NRI for last 15 years and received summon u/s 131(1A) for FY 2021 to FY2024. Without disclosing any details, the summons ask for following: Sources of Income earned by me and my family members in India & outside India Details of interest earned by me and my family members on NRE/NRO/FD/FCNR/HUF account All property dealings during this period All Bank account statement Details of any business conducted by me in India Copies of my and my family member passports All property documents which are held by me and my family members I understand that as NRI, I am not required to disclose my overseas income. I am willing to provide details of my India sourced Income which are disclosed in my tax returns and offered for taxes in relevant year. I have India sourced interest from NRO/NRE/FCNR exceeding INR 15L. Will it attract provision of section 6(1A)? I am a tax resident of UAE which impose no personal income tax. If provision of section 6(1A) is attracted, which all income shall be taxed in India. Will FCNR interest be included for calculation of INR 15L threshold? I split my earnings in UAE with my spouse (NRI) who then invests it in India. Will it attracts clubbing provision? My view is that my offshore income gifting to my NRI family members and their subsequent earnings thereon should not attract any clubbing provisions? Is there any provision of Income Tax Act which requires me to disclose my foreign income under 131(1A) summons?

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Re easementary right of way on agriculture land, please advise if the below and related the Acts /sections- 1. easementary rights Not applicable in agriculture lands. 2. civil court do not have jurisdiction on matters related to agriculture lands also the easementary rights being claimed on agriculture land 3. Permanent injunction cannot be granted by court if the easementary right is not established 4. right of way can not be claimed after consolidation is completed U/S49 UP Revenue Act

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a registered firm purchased some item from a registered dealer having valid GST number, the goods were delivered through E-WAY BILL, but while making payments after some time assessee came to know that firm has been closed and registration is also cancelled therefore payment could not be made during the relevant financial year and shown as outstanding in his balance sheet. The department treated this as bogus transaction and added to his income after issuing 142(2) followed by 148, therefore a huge demand is created. the department issued a demand stating that if total demand along with interest is deposited with in 30 days then no penalty proceeding will be initiated. accordingly assessee deposited the entire amount within specified time , but later on department has issued notice for initiating proceedings u/s 271(1) c. please suggest what steps to be taken

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Whether imposition of tax on subsidy and concessions under amended provision of section 2(24)(xviii) (Finance Act 2015)

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Whether builder developer is required to deduct tax on amount paid to the existing members by way of rent for alternative accommodation as well as corpus and other sum paid as part of development agreement?

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Mr. A is a proprietor of various business having different trade name and place of business but the nature of business is same.  Can he transfer the business to M/s. A Ltd company after retaining immovable property in his name so no capital gain tax is payable. Is it necessary to transfer it’s entire business with all assets and liabilities to the A Ltd company?

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A resident paying rent to NRI, deducting TDS @ 31.20%. However at the time of filing return (form 27Q), he did not mention the PAN and straight away mentioned “PAN not available” At what rate TDS is deductible ?

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In Case of Transfer ownership of Land to Developers by Landowner (Individual) against consideration in Area and some money.   Q1. whether this is covered under Section 45 (5A), as it is not a Development Agreement?   Q2. In this Case Developers Purchase Capital Asset – Land from Landowner and Developers name will be mentioned on Revenue Record as Landowner?   Q3. Whether Landowner Income Tax Liability will postponed to Future Date on the date of OC

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My father sold a land property on his name and purchased a flat on his name with entire sale consideration. Now, Section 54F says he should not sell it within three year But can he gift the flat through gift deed in my name or should we wait for three years for gift transaction also? References of relevant cases will help a lot. Thanks.

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