ADVANCED DIRECT TAX LAWS AND PRACTICE
Advanced Direct Tax Laws and Practice (One hundred marks)
ARRANGEMENT OF STUDY LESSONS ADVANCED DIRECT TAX LAWS AND PRACTICE Group One Elective Paper Four Point Five
ROLE OF COMPANY SECRETARIES IN DIRECT TAX LAW
Lesson One: Computation of Total Income, Tax Liability and Filing of Returns of various entities excluding Companies
Lesson Two: Computation of Total Income, Tax Liability and Filing of Return of Companies
Lesson Three: Income Tax Implication on specified transactions
Lesson seven: Transfer Pricing and General Anti Avoidance Rules "GAAR"
Lesson eight: Double Taxation Avoidance Agreement (DTAA)
ADVANCED DIRECT TAX LAWS AND PRACTICE
LESSON THREE INCOME TAX IMPLICATION ON SPECIFIED TRANSACTIONS
Taxation of Dividend Income one hundred forty-six
Tax Implication in case of Dividend Income one hundred forty-eight
Taxability of Dividend in hands of Recipient
Taxable in the hands of Resident Shareholder
Taxability in case of Non-Resident shareholders including FPIs
Special provision for computation of Capital Gains in case of Slump Sale [Section fifty B] Related Rule(s)
Slump Sale and Capital Gain Tax
Issue of Shares at Premium
Special provision for full value of consideration for transfer of share other than quoted share [Section fifty CA]
Mode of Computation [Section forty-eight]
Reduction of Share Capital
Carbon Credit [Section one hundred fifteen BBBG]
Charge of Equalisation levy on specified services [Section one hundred sixty-five]
Collection and recovery of Equalisation levy on specified services [Section one hundred sixty-six] one hundred seventy-one
Collection and recovery of Equalisation levy on e-commerce supply or services [Section one hundred sixty-six A]
Aspects of Amalgamations, Mergers and Demergers
Capital Gains one hundred seventy-seven
Carry Forward and Set Off of Accumulated loss and unabsorbed depreciation of the amalgamating company [Section seventy-two A]
Procedure for Faceless Assessment [Section one hundred forty-four B one]
Income Escaping Assessment or Re-Assessment i.e., Re-Opening of Cases [Section one hundred forty-seven] two hundred sixty-seven
Analysis of Section one hundred forty-eight A - Conducting inquiry, providing opportunity before issue of notice under Section one hundred forty-eight
Issue of Notice [Section one hundred forty-eight]
Conditions to be fulfilled before issue of notice
Time limit for issue of Notice under Section one hundred forty-eight [Section one hundred forty-nine]
Unlimited Time Limit to Issue Notice [Section one hundred fifty]
Analysis of Section one hundred fifty - Unlimited Time Limit to Issue Notice
Section one hundred fifty-one - Sanction for issue of notice
Tax Rate applicable for Escaped Income [Section one hundred fifty-two one]
Time Limit to complete Assessment and Reassessment [Section one hundred fifty-three]
Rectification of Mistakes [Section one hundred fifty-four]
Demand Notice [Section one hundred fifty-six]
Period of Limitation to prefer an Appeal before Joint Commissioner (Appeals) or Commissioner Appeal [Section two hundred forty-nine two]
Faceless Appeal [Section two hundred fifty six B]
How to file Rectification
Powers of the Joint Commissioner (Appeals) or Commissioner (Appeals) (Section two hundred fifty-one)
Appealable Orders Before ITAT [Section two hundred fifty-three one and two]
Rectification of Appellate Order
Faceless Proceedings before ITAT
Faceless Proceedings before ITAT
Provision for Avoiding Repetitive Appeals (Section one hundred fifty-eight A)
LESSON SEVEN TRANSFER PRICING AND GENERAL ANTI AVOIDANCE RULES "GAAR"
Associated Enterprises (AE)
"Multiple Year Data" and Range Concept
Computation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies
Special Tax Regime Applicable to a Co-operative Societies
Taxation of Hindu Undivided Families 'HUF'
Persons who have to compulsorily file the Return of Income
Consequences for late filing of Return of Income
Payment of Self-Assessment Tax before filing Return of Income
Alternate Minimum Tax 'AMT'
Taxation of Co-operative Societies
Four. For Firm and Local Authorities:
Marginal Relief in Surcharge
Health and Education Cess 'HEC'
SPECIAL TAX REGIME FOR INDIVIDUAL, HUFs, AOP, BOI, ARTIFICIAL JURIDICAL PERSON [SECTION ONE HUNDRED FIFTEEN BAC]
SPECIAL TAX REGIME APPLICABLE TO A CO-OPERATIVE SOCIETIES [SECTION ONE HUNDRED FIFTEEN BAD]
TAX ON INCOME OF CERTAIN NEW MANUFACTURING CO-OPERATIVE SOCIETIES
Special Tax Rates which are Taxable at Fixed Rates (Applicable for Both Regime)
Computation of Taxable Income of Mr. X for the A.Y. two thousand twenty-six to two thousand twenty-seven
A. Computation of Total Income
Computation of total income of Mr. X for the assessment year twenty twenty-six to twenty-seven
A Hindu Joint Family consists of two types of members:
Position under Hindu Succession Act, nineteen fifty-six
The preferential heirs of class one are as under:
COMPUTATION OF INCOME OF HINDU UNDIVIDED FAMILY 'HUF'
Joint Property of the family consists of:
Partition of a Hindu Undivided Family [Section one hundred seventy-one]
Who is entitled to share on partition?
Assessment after partition [Section one hundred seventy-one]
Option one: Assessee has opted to pay tax as per the old scheme:
Assessment as a Firm [Section one hundred eighty-four]
Computation of Income and Tax Liability of Firm
Meaning of Book Profit [Explanation three to section forty B]
Provision for Brought forward business losses
Computation of allowable remuneration under section forty B
Succession of one firm by another firm [Section one hundred eighty-eight]
Joint and Several Liabilities of Partners for Tax Payable by Firm [Section one hundred eighty-eight A]
Firm Dissolved or Business Discontinued [Section one hundred eighty-nine]
Computation of Book-Profit
Computation of Total Income of Lawyers and Company for A. Y. twenty twenty-six minus twenty-seven
Option one: Assessee paying tax under old tax regime
Option one: Assessee paying tax under old tax regime
Computation of Normal Tax
Computation of Normal Tax
Computation of Total Income, Tax Liability and Filing of Returns of various Entities excluding Companies LESSON one
Calculation of Business Income
Computation of tax liability and adjustment of FTC
TAXATION OF ASSOCIATION OF PERSONS / BODY OF INDIVIDUALS
Tax Liability of Association of Persons / Body of Individuals
Section one hundred sixty-seven B makes the following provisions as regards the incidence of charge of tax on the association of persons.
B. Where the Shares of the Members are Indeterminate
Method of Computing Share of Member of Association of Persons / Body of Individuals Section sixty-seven A
Taxation of share of income of a member of association of persons or body of individuals
Assessment in case of Dissolution of an Association of Persons [Section one hundred seventy-seven]
TAXATION OF CO-OPERATIVE SOCIETIES
Computation of Income of Co-operative Societies
Rates of Income-tax on Co-operative Society
Deduction in respect of Income of Co-operative Societies [Section eighty-OP]
Urban Consumers' Co-operative Society
Assessment of Co-operative Societies
Manner and Mode of Filing Return of Income
Compulsory Filing of Income Tax Return [Section one thirty-nine one]
Compulsorily filing of Return of Income or Loss
Due Date for Filing Income Tax Return [Section one thirty-nine one]
TECHNOLOGICAL ASPECTS IN TAX COMPLIANCES
Enhanced Compliance and Enforcement
Benefits of Technological Innovations in Tax Compliance
The provision related to Filing of Return of Income.
Meaning of Company [Section two of the Income-tax Act, nineteen sixty-one]
Domestic Company [Section two twenty-two A]
Prescribed arrangements for declaration and payment of dividends within India [Rule twenty-seven]
Indian Company [Section two twenty-six]
TAX INCIDENCE ON COMPANIES
Guiding Principles for determining Place of Effective Management
Explanation: For the aforesaid purpose:
Some of the guiding principles for determining the POEM
For Detailed POEM Guidelines:
Following Deduction not allowed while calculating total Income
MINIMUM ALTERNATE TAX (MAT)
MAT provision shall not apply to:
The amount of Income-tax shall include:
Meaning of book profit for Indian Accounting Standards compliant companies.
MAT CREDIT [SECTION one hundred fifteen JAA]
Concessional Rate of MAT for IFSC unit
Carried Forward of MAT Credit
MAT Provisions for Converted LLPs and Exemptions
Exemption from filing Income Tax Return by Foreign Companies in certain cases
Conditions for claiming exemption for filing Income Tax Return
Return of Loss under section one hundred thirty-nine three
Compulsory Filing of Return of Loss for on or before the due date to carry forward and set-off certain losses
Belated Return under section one hundred thirty-nine four
Revised Return under section one hundred thirty-nine five
Defective Return [Section one hundred thirty-nine nine]
Updated Return [Section one hundred thirty-nine eight A]
Three. Circumstances in which updated return can not be Furnished:
Tax on Updated Return [Section one hundred forty B]
Where Return of Income is Furnished earlier [Section one hundred forty-two B two]
Additional Income Tax Payable at the time of Updated Return [Section one hundred forty B three]
Fee for default in Furnishing Return of Income [Section two hundred thirty-four F]
VERIFICATION OF RETURN OF INCOME IN CASE OF COMPANIES [SECTION one hundred forty]
Multiple Choice Questions "M C Qs"
Income Tax Implication on Specified Transactions
Tax Implication in case of Restructuring of Business Amalgamation or Merger or De-merger
TAXATION OF DIVIDEND INCOME
Taxability in hands of Shareholders
Taxability of Dividend in the hands of Company
Tax Implication in case of Dividend Income
From first April two thousand twenty
Taxability of Dividend in hands of Recipient
Taxable in the hands of Resident Shareholder
Taxability in case of non-resident shareholders including FPIs
Tax Implication of Buy Back of Shares
What will be tax treatment in the hands of shareholder receiving this consideration and in hands of the company.
Understanding of provisions with regard to Slump Sale
Special provision for computation of Capital Gains in case of Slump Sale [Section fifty B]
SLUMP SALE AND CAPITAL GAIN TAX
Balance sheet as on thirty-first March twenty sixty-six
Ascertain the tax liability, which would arise from slump sale to ABC Limited.
Computation of Net Worth of Service Unit-
Relevant provision of Section fifty-six with regard to Share Premium Amount
Explanation: For the purposes Section fifty-six sub-section two sub-section B
Mode of Computation [Section forty-eight]
REDUCTION OF SHARE CAPITAL
Find out the amount of depreciation and capital gain chargeable to tax for the assessment year twenty twenty-six to twenty-seven. Solution:
CARBON CREDIT [SECTION one hundred fifteen B B G]
Coverage and Applicability
Charge of equalisation levy on specified services [Section one sixty-five]
Charge of equalisation levy on e-commerce supply of services [Section one sixty-five A]
Collection and recovery of equalisation levy on specified services [Section one sixty-six]
Collection and recovery of equalisation levy on e-commerce supply or services [Section one hundred sixty-six A]
Furnishing of statement [Section one hundred sixty-seven]
ASPECTS OF AMALGAMATIONS, MERGERS AND DEMERGERS
Carry Forward and Set Off of Accumulated loss and unabsorbed depreciation of the amalgamating company [Section seventy-two A]
Ensure Compliances of the provisions of Income Tax Act
Explanation. - For the purposes of this section,
DETAILED ANALYSIS OF SECTION forty-four A B
Tax Audit under section forty-four A B of the Income-tax Act is applicable in the following cases:
Non-Applicability of Tax Audit
WHO CAN CONDUCT TAX AUDIT "ACCOUNTANT"
Analysis of definition and eligibility of 'Tax Auditor'
Services referred in section one hundred forty-four are:
MEANING OF IMPORTANT TERM
Gross Receipts for Profession
Reimbursements vs Recoveries
Special Aspects - Speculative Transactions
Applicability of Provisions:
Analysis of the Current Situation:
MAINTENANCE OF BOOKS OF ACCOUNTS [SECTION forty-four AA]
List of books of accounts required to be maintained
Where books of account and other documents should be kept and maintained?
Penalty for non-compliance
Changes Introduced via Finance Act, twenty twenty-five
Eleven. Section eighty-seven A (Rebate)
Impact on Tax Audit Applicability
FORM NUMBER three CB [See rule six G one b]
FORM three CD - Statement of Particulars required to be furnished under section forty-four AB
FAILURE TO FURNISH TAX AUDIT REPORT [SECTION two hundred seventy-one B]
Following are some instances of "reasonable cause" as laid down by Tribunals and Courts:
Three. Procedure to approve Tax Audit Report
Section two hundred seventy-one B of The Income-Tax Act, nineteen sixty-one - Penalty for failure to get accounts audited
OTHER REFERENCES (INCLUDING WEBSITES AND VIDEO LINKS)
Time Limit to complete the Assessment, Re-assessment and Re-computation
Rectification of Mistakes
SELF-ASSESSMENT [SECTION ONE HUNDRED FORTY A]
Adjustments required to compute Self-Assessment Tax Payable under section one hundred forty A:
Computation of Self-Assessment Tax (S.A.T.) payable under section one forty A
INQUIRY BEFORE ASSESSMENT [SECTION ONE FORTY-TWO]
Notice under Section one forty-two one
One. Issue of notice to the assessee to submit return (if not submitted earlier):
Reliance Textiles Limited.
Analysis of Section one hundred forty-two A - Estimation of Value of Assets by Valuation Officer (VO)
Summary Assessment/ Processing of Return [Section one hundred forty-three one]
Analysis of Section one hundred forty-three one - Summary Assessment/ Processing of Return
Order of Scrutiny Assessment [Section one hundred forty-three three]
Assessment Process Section one hundred forty-three three
Special Cases - Tax-Exempt Institutions
BEST JUDGEMENT ASSESSMENT [SECTION ONE HUNDRED FORTY-FOUR]
FACELESS ASSESSMENT [SECTION ONE HUNDRED FORTY-FOUR B]
INCOME ESCAPING ASSESSMENT OR RE-ASSESSMENT I.E., RE-OPENING OF CASES [SECTION ONE HUNDRED FORTY-SEVEN]
Introduction of Block Assessment (Effective September first, twenty twenty-four):
Section one hundred forty-eight two. Nature of return
Section one hundred forty-eight three. What qualifies as "information" for escapement
CONDUCTING INQUIRY, PROVIDING OPPORTUNITY BEFORE ISSUE OF NOTICE UNDER SECTION ONE HUNDRED FORTY-EIGHT [SECTION ONE HUNDRED FORTY-EIGHT A]
Time Limit to Issue Notice under Section one hundred forty-eight A [Section one hundred forty-nine two]
Authority granting sanction for issue of Notice under Section one hundred forty-eight A
Analysis of Section one hundred forty-eight A - Conducting inquiry, providing opportunity before issue of notice under Section one hundred forty-eight
ISSUE OF NOTICE [SECTION ONE HUNDRED FORTY-EIGHT]
Issuance of Notice for Escaped Income (Section one hundred forty-eight)
Conditions for Issuing Notice
"Information" Suggesting Escaped Income
Analysis of Section one hundred forty-eight
Conditions to be fulfilled before issue of notice
Cases where it shall be deemed that AO having information which suggest the income has escaped assessment-
Prior approval for assessment, reassessment or re-computation in certain cases under Section one hundred forty-eight B
Time limit for issue of Notice under Section one hundred forty-nine
Unlimited time limit to issue notice under Section one hundred fifty
Analysis of Section one hundred fifty - Unlimited Time Limit to Issue Notice
Section one hundred fifty-one - Sanction for issue of notice
Faceless assessment of income escaping assessment under Section one hundred fifty-one A
Tax rate applicable for escaped income under Section one hundred fifty-two one
DROPPING OF ASSESSMENT PROCEEDING [SECTION ONE HUNDRED FIFTY-TWO( TWO)]
TIME LIMIT TO COMPLETE ASSESSMENT AND REASSESSMENT [SECTION ONE HUNDRED FIFTY-THREE]
Time limit for Completion
RECTIFICATION OF MISTAKES [SECTION ONE HUNDRED FIFTY-FOUR]
Analysis of Section One Hundred Fifty-Four - Rectification of Mistakes
DEMAND NOTICE [SECTION ONE HUNDRED FIFTY-SIX]
Application based Questions
OTHER REFERENCES (INCLUDING WEBSITES AND VIDEO LINKS)
APPEALABLE ORDERS BEFORE JOINT COMMISSIONER (APPEALS) (SECTION TWO HUNDRED FORTY-SIX)
APPEALABLE ORDERS BEFORE COMMISSIONER (APPEALS) (SECTION TWO HUNDRED FORTY-SIX A)
PROCEDURE FOR FILING AN APPEAL BEFORE JOINT COMMISSIONER (APPEALS) OR COMMISSIONER APPEAL [SECTION TWO HUNDRED FORTY-NINE ONE]
PERIOD OF LIMITATION TO PREFER AN APPEAL BEFORE JOINT COMMISSIONER (APPEALS) OR COMMISSIONER APPEAL [SECTION two hundred forty-nine two]
PAYMENT OF TAX BEFORE FILING APPEAL [SECTION two hundred forty-nine four]
PROCEDURE IN APPEAL (SECTION TWO FIFTY)
Rule forty-six A Production of additional evidence before the Joint Commissioner (Appeals) and Commissioner (Appeals)
Decision and Order of Joint Commissioner (Appeals) or CIT (Appeals)
FACELESS APPEAL (SECTION TWO FIFTY SIX B)
Notification of the Scheme of Faceless Appeals
Procedure of Conduct of Faceless Appeals
No personal appearance in the Appeal Centres or Units and Vested Right of Personal Hearing through Video Conferencing
How to file Rectification
Grievance redressal mechanism
Appellate Tribunal (SECTION TWO HUNDRED FIFTY-TWO)
APPEALABLE ORDERS BEFORE ITAT [SECTION TWO HUNDRED FIFTY-THREE ONE AND TWO]
PROCEDURE FOR FILING APPEAL BEFORE APPELLATE TRIBUNAL [SECTION TWO HUNDRED FIFTY-THREE THREE, FOUR, AND SIX]
Form of appeal and memorandum of cross-objections to Appellate Tribunal
Filing of Additional Evidence
ORDER OF APPELLATE TRIBUNAL (SECTION TWO FIFTY-FOUR)
Rectification of Appellate Order
Faceless Proceedings before ITAT
PROCEDURE OF APPELLATE TRIBUNAL (SECTION TWO HUNDRED FIFTY-FIVE)
FACELESS PROCEEDINGS BEFORE ITAT
PROVISION FOR AVOIDING REPETITIVE APPEALS (SECTION ONE HUNDRED FIFTY-EIGHT A)
APPEAL BEFORE HIGH COURT (SECTION two hundred sixty A and two hundred sixty B)
APPEAL BEFORE SUPREME COURT (SECTION two hundred sixty-one)
REVISION BY THE COMMISSIONER OF INCOME TAX (SECTIONS two hundred sixty-three AND two hundred sixty-four)
REVISION OF ORDERS PREJUDICIAL TO THE INTEREST OF REVENUE (SECTION two hundred sixty-three)
REVISION OF ORDER IN THE INTEREST OF ASSESSEE (SECTION TWO HUNDRED SIXTY-FOUR)
One. Revision of order of subordinate authority only (Section two hundred sixty-four one and Explanation two)
Two. Suo moto Revision (Section two hundred sixty-four one and two)
Three. Revision on application of the Assessee (Section two hundred sixty-four one, three and five)
Four. Nature of the order (Section two hundred sixty-four)
Circumstances in which no revision can be made [Section two hundred sixty-four(four)]
Remedy against the revisional order
Faceless revision of order (Section two hundred sixty-four A)
Faceless effect of order (Section two hundred sixty-four B)
Monetary limit for regulating filing an appeals by income tax authorities (Section two hundred sixty-eight A)
No punishment if proved that there was reasonable cause for failure (Section two hundred seventy-eight A A)
Provision for Bank Guarantee (Section two hundred eighty-one B)
Introduction and Importance
Practical difficulties in Application of Arm's Length Price?
Meaning of International Transaction
Specified Domestic Transaction (Section ninety-two B A)
Selection of Transfer Pricing Methods
Advance Pricing Agreement [Section ninety-two C C]
Transfer Pricing Documentation
A Introduction and Background
Chapter Ten-A of Income Tax Act, nineteen sixty-one
One Current Scenario with Specific Anti Avoidance Rules "SAAR"
Misc. Aspects of GAAR Provisions
A List of Further Readings
IMPORTANCE OF TRANSFER PRICING
TRANSFER PRICING PROVISIONS IN INDIA
PRACTICAL DIFFICULTIES IN APPLICATION OF ALP
Deemed Associated Enterprises
MEANING OF INTERNATIONAL TRANSACTION
(one) Deemed international transaction [Section ninety-two B two]
Explanation. - For the removal of doubts, it is hereby clarified that -
(ii) the expression "intangible property" shall include -
TRANSFER PRICING - APPLICABILITY TO DOMESTIC TRANSACTIONS
TRANSFER PRICING - METHODS
Computation of Arm's Length Price
Transactional Profit Methods
Comparable Uncontrolled Price Method
Applicability of the CUP Method
Now, arm's length price is determined as under:
Increase in income of Alfa Laval India Ltd.
Two step Approach of Profit Split Method
Example on the Profit Split Method (Residual Analysis Approach)
Step one - Determining the basic return
Step two: Dividing the residual profit
(e) Transactional Net Margin Method (TNMM)
Transfer price based on TNMM
SELECTION OF TRANSFER PRICING METHOD
Functional analysis also forms part of the documentation. The major components of a functional analysis are:
Computation of Arm's Length Price in Certain Cases [Rule ten CA]
REFERENCE TO TRANSFER PRICING OFFICER
Who is Transfer Pricing Officer
Determination of Arm's Length Price by Transfer Pricing Officer
Extension of Time Limit to Transfer Pricing Officer in Certain Cases
Rectification of Arm's Length Price Order by Transfer Pricing Officer
Powers of Transfer Pricing Officer
Eight. Power to levy penalty for failure to furnish information
Nine. Power of Board to Make Safe Harbour Rules
ADVANCE PRICING AGREEMENT (SECTION NINETY-TWO C C)
Calculation of Arm's Length Price under Advance Pricing Agreement
Validity of Advance Pricing Agreement
Bindingness of Advance Pricing Agreement
Declaring an Advance Pricing Agreement Void Ab Initio
Effect of Declaring an Advance Pricing Agreement Void Ab Initio
Procedure and Scheme of Advance Pricing Agreement
ROLL BACK PROVISION IN ADVANCE PRICING AGREEMENT
"Multiple Year Data" and Range Concept
Application of the Range Concept
Filing of Modified Return for Any Assessment Year relevant to Previous Year to which APA applies
Extension of limitation period in the cases where modified return is filed under Section ninety-two C D
Secondary Adjustment in certain International Transactions [Section ninety-two C E]
Secondary adjustment is not required, if following conditions are satisfied [Threshold limit]:
Quantification of Secondary adjustment "on Part" [Section ninety-two C E two]
TRANSFER PRICING - DOCUMENTATION
Submission of Documents with the Tax Authorities
Non-Applicability of Documentation Requirement
Retention Period of Documents Kept under Rule ten D
Report from an Accountant [Section ten E]
SAFE HARBOUR RULES [SECTION ninety-two CB]
Safe harbour carry certain benefits which are described below:
Filling of form three CEFA / three CEFB
TRANSFER PRICING - PENALTY FOR CONTRAVENTION
B. Penalty for failure to furnish information or document - Section two hundred seventy-one G
D. Penalty for failure to furnish report under Section ninety-two E - Section two hundred seventy-one BA
Compute arm's length price as per cost plus method and the amount of increase in total income of Hitech Ltd.
TAX EVASION VERSUS TAX AVOIDANCE
IMPERMISSIBLE AVOIDANCE AGREEMENT
CURRENT SCENARIO WITH SPECIFIC ANTI AVOIDANCE RULES (SAAR)
Bond washing Transaction under section ninety-four one
The following are some distinguishing features between GAAR and SAAR.
GAAR [General Anti-Avoidance Rules]
Key extracts / inferences from Supreme Court Judgement
International Transaction
MISCELLANEOUS ASPECTS OF THE GAAR PROVISIONS
Judicial anti-avoidance in a GAAR era
Clarifications on implementation of GAAR provisions under the Income Tax Act, nineteen sixty-one [Circular Number seven of twenty seventeen]
Juridical Double Taxation
Country wise Double Taxation Avoidance Agreements entered by INDIA :
BILATERAL RELIEF FROM DOUBLE TAXATION
UNILATERAL RELIEF FROM DOUBLE TAXATION
AGREEMENTS WITH FOREIGN COUNTRIES OR SPECIFIED TERRITORIES OUTSIDE INDIA - BILATERAL RELIEF [SECTION NINETY]
ADOPTION BY CENTRAL GOVERNMENT OF AGREEMENT BETWEEN SPECIFIED ASSOCIATIONS FOR DOUBLE TAXATION RELIEF [SECTION NINETY A]
DOUBLE TAXATION RELIEF WHERE THERE IS AN NO DTAA AGREEMENT [SECTION NINETY-ONE]
Indian Tax on Doubly Taxed Income:
Foreign Tax on Doubly Taxed Income:
CALCULATION OF RELIEF FROM DOUBLE TAXATION
OBJECTIVES OF TAX TREATIES
CONCEPT OF PERMANENT ESTABLISHMENT
Significant Articles covered in the Model Conventions
Permanent Establishment Discussed earlier in this chapter
Income from the operation of ships or aircraft in international traffic and boats in inland waterways transport
INTERPRETATION OF TAX TREATIES
PROFESSIONAL PROGRAMME ADVANCED DIRECT TAX LAWS AND PRACTICE GROUP ONE ELECTIVE PAPER FOUR point five
OR (Alternate to Question Number four)
Attempt all the parts of either Question Number six or Question Number six A
OR (Alternate to Question Number six)