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Analysis of judgement of Supreme Court delivered on 15.12.2025 in the case of Director of Income Tax, Mumbai v. M/s American Express Bank Ltd., on the issue of Deduction of head office expenditure in the case of non-residents under section 44C of the Income Tax Act, 1961
Analysis of judgement of Supreme Court delivered on 15.12.2025 in the case of Director of Income Tax, Mumbai v. M/s American Express Bank Ltd., on the issue of Deduction of head office expenditure in the case of non-resi...
Tie breaker Rule in Double Taxation Avoidance Agreement (DTAA)
Tie breaker Rule in Double Taxation Avoidance Agreement (DTAA)The Tie breaker rule for residential status refers to the criteria used to determine an individual’s primary place of residence, usually for tax purpos...
Whether Sumptuary allowance granted to judicial officer is exempt from payment of Income Tax?
Whether Sumptuary allowance granted to judicial officer is exempt from payment of Income Tax?The sumptuary allowance is a specific benefit provided to judicial officers in India to cover entertainment expenses. This allo...
Capital gain exemption on transfer of long-term capital asset (other than residential house) [Section 54F of Income-tax Act, 1961]
Capital gain exemption on transfer of long-term capital asset (other than residential house) [Section 54F of Income-tax Act, 1961]Section 54F of Income-tax Act, 1961 grants exemption from long-term capital gains (LT...
Specific mechanism for Secondary Adjustments rules in Indian Transfer Pricing regime [Section 170 of the Income Tax Act, 2025
Specific mechanism for Secondary Adjustments rules in Indian Transfer Pricing regime [Section 170 of the Income Tax Act, 2025Section 170 of the Income Tax Act, 2025 provides that a secondary adjustment shall be made in c...
Principle of Peak Credit Theory under Income Tax Act, 1961 – Complete Analysis with Landmark Case Laws, Section 68 & Judicial Findings
Principle of the Peak Credit Theory in Income TaxMeaning of Peak credit theory :§ Instead of taxing entire deposits, only the maximum unexplained balance (peak) is taxed§ Because wi...
Presumptive Taxation under the Income‑tax Act, 2025 — Rationale, History, Use & Misuse, and International Comparisons
Presumptive
Taxation under the Income‑tax Act, 2025 — Rationale, History, Use & Misuse,
and International ComparisonsAbstract
This article examines presumptive taxation under the Income‑tax Act, 2025. It
is...
Whether Sumptuary allowance granted to judicial officer is exempt from payment of Income Tax?
Whether Sumptuary allowance granted to judicial officer is exempt from payment of Income Tax?The sumptuary allowance is a specific benefit provided to judicial officers in India to cover entertainment expenses. This allo...
Tie breaker Rule in Double Taxation Avoidance Agreement (DTAA): Determination of Tax Residence in Dual Residency Cases with Key Judicial Precedents
Tie breaker Rule in Double Taxation Avoidance Agreement (DTAA)The Tie breaker rule for residential status refers to the criteria used to determine an individual’s primary place of residence, usually for tax purpos...
Appeal Maintainable Despite Low Tax Effect Due to Accommodation Entry Exception: Delhi High Court in Pr. CIT-1 v. Agroha Fincap Ltd. (ITA No. 60/2024, 23.12.2025)
Delhi High Court:-Pr. Commissioner
of Income Tax – 1 VersusM/s Agroha Fincap Ltd.ITA No. 60/2024 | Judgment dated: 23 December 2025 CORE ISSUE:-Whether the appeal
filed by the Revenue before the High Court was m...