Taxmann’s Handbook on Taxation of Partnership Firms & LLPs: FAQs – The one-of-a-kind book covering 360 FAQs, exhaustively dealing with Section 9B & 45(4) of the Income-tax Act along with Case Studies PDF Download
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Author: Adv. Shashi Ashok Bekal Publisher: Taxmann Publications Private Limited ISBN: 9392211228 Category : Law Languages : en Pages : 61
Book Description
This unique/one-of-a-kind book covers 360 frequently asked questions (FAQs) on the contentious subject of Taxation of Partnership Firms & Limited Liability Partnerships. It is the only publication in the country that exhaustively deals with the new provisions of Section 9B and Section 45(4) of the Income-tax Act, 1961 & General Law. This book will serve as a helpful reference and guide for Lawyers, Chartered Accountants, Tax Practitioners, Taxpayers, and the Officers of the Tax Department. The Present Publication is the 2022 Edition, edited by Dr K. Shivaram & authored by Adv. Shashi Ashok Bekal, with the following noteworthy features: • [360 Frequently Asked Questions] on taxation of Partnership Firms & Limited Liability Partnerships • [Exhaustive Coverage] The book is divided into 24 Chapters viz: o Admission of a Partner o Dissolution of a Partnership Firm o Reconstitution of a Partnership Firm, etc. • [Case Study] To provide clarity on Section 9B and Section 45(4), the following case studies are included in this book: o Application of Section 45(4) of the Income-tax Act o Application of Section 9B & Section 45(4) of the Income-tax Act o Computation of Capital Gain tax under Section 45(4) of the Income-tax Act; Attribution of Profits under Section 45(4) • [Implication of Other Laws] vis-à-vis Partnership Firms & Limited Liability Partnerships: o Stamp duty o Goods & Services Tax (GST) o Foreign Exchange Management Act (FEMA) o Labour Laws Reviewed by the following Eminent Personalities • Hon’ble Justice Rajesh Bindal | Chief Justice – Allahabad High Court “… It is an effort to make complex issues of taxation easier. This publication is in FAQ Format and aims at addressing not only the ambiguities arising from the amendments vide the Finance Act, 2021 vis-à-vis Partnership Firms, LLPs, etc. but will prove to be a tool for tax consultants, tax administrators, taxpayers and all others concerned with the subject…” • Hon’ble Justice R.K. Agarwal | Former Judge – Supreme Court of India & President | NCDRC “… The book contains detailed information in FAQ format with respect to various provisions of the Partnership firm. I appreciate the pain taken by the Authors to do a lot of hard work and research before writing such a useful Handbook…” The contents of the book are as follows: • General • Operational Issues • Issues on Residency • Compliances • Registration and Inception of a Partnership Firm/Limited Liability Partnership • Section 9B of the Income-tax Act, 1961 • Section 45(4) of the Income-tax Act, 1961 • The interplay between section 9B & section 45(4) of the Income-tax Act, 1961 • Admission of a Partner • Retirement of a Partner • Expulsion, Death and Insolvency of a Partner • Reconstitution of a Partnership Firm • Dissolution of a Partnership Firm • Conversion of a Partnership Firm • Set-off and Carry Forward of Losses • Gift Implications • Liability and Prosecution • Stamp Duty Implications • Goods & Services Tax (GST) Implications • Labour Law Implications • Association of Persons and Body of Individuals • Miscellaneous • Specimens • Case Studies
Author: Adv. Shashi Ashok Bekal Publisher: Taxmann Publications Private Limited ISBN: 9392211228 Category : Law Languages : en Pages : 61
Book Description
This unique/one-of-a-kind book covers 360 frequently asked questions (FAQs) on the contentious subject of Taxation of Partnership Firms & Limited Liability Partnerships. It is the only publication in the country that exhaustively deals with the new provisions of Section 9B and Section 45(4) of the Income-tax Act, 1961 & General Law. This book will serve as a helpful reference and guide for Lawyers, Chartered Accountants, Tax Practitioners, Taxpayers, and the Officers of the Tax Department. The Present Publication is the 2022 Edition, edited by Dr K. Shivaram & authored by Adv. Shashi Ashok Bekal, with the following noteworthy features: • [360 Frequently Asked Questions] on taxation of Partnership Firms & Limited Liability Partnerships • [Exhaustive Coverage] The book is divided into 24 Chapters viz: o Admission of a Partner o Dissolution of a Partnership Firm o Reconstitution of a Partnership Firm, etc. • [Case Study] To provide clarity on Section 9B and Section 45(4), the following case studies are included in this book: o Application of Section 45(4) of the Income-tax Act o Application of Section 9B & Section 45(4) of the Income-tax Act o Computation of Capital Gain tax under Section 45(4) of the Income-tax Act; Attribution of Profits under Section 45(4) • [Implication of Other Laws] vis-à-vis Partnership Firms & Limited Liability Partnerships: o Stamp duty o Goods & Services Tax (GST) o Foreign Exchange Management Act (FEMA) o Labour Laws Reviewed by the following Eminent Personalities • Hon’ble Justice Rajesh Bindal | Chief Justice – Allahabad High Court “… It is an effort to make complex issues of taxation easier. This publication is in FAQ Format and aims at addressing not only the ambiguities arising from the amendments vide the Finance Act, 2021 vis-à-vis Partnership Firms, LLPs, etc. but will prove to be a tool for tax consultants, tax administrators, taxpayers and all others concerned with the subject…” • Hon’ble Justice R.K. Agarwal | Former Judge – Supreme Court of India & President | NCDRC “… The book contains detailed information in FAQ format with respect to various provisions of the Partnership firm. I appreciate the pain taken by the Authors to do a lot of hard work and research before writing such a useful Handbook…” The contents of the book are as follows: • General • Operational Issues • Issues on Residency • Compliances • Registration and Inception of a Partnership Firm/Limited Liability Partnership • Section 9B of the Income-tax Act, 1961 • Section 45(4) of the Income-tax Act, 1961 • The interplay between section 9B & section 45(4) of the Income-tax Act, 1961 • Admission of a Partner • Retirement of a Partner • Expulsion, Death and Insolvency of a Partner • Reconstitution of a Partnership Firm • Dissolution of a Partnership Firm • Conversion of a Partnership Firm • Set-off and Carry Forward of Losses • Gift Implications • Liability and Prosecution • Stamp Duty Implications • Goods & Services Tax (GST) Implications • Labour Law Implications • Association of Persons and Body of Individuals • Miscellaneous • Specimens • Case Studies
Author: Dr. Neha Pathakji Publisher: Taxmann Publications Private Limited ISBN: 9357781838 Category : Education Languages : en Pages : 32
Book Description
This book is a comprehensive & authentic textbook on 'Taxation Laws' as amended by the Finance Act 2023. This book aims to represent an impressive and judicious blending of the provisions of Income Tax & judicial decisions. The text is interspersed with interpretations, explanations & illustrations to help the reader assimilate the provisions better. This book aims to fulfil the requirement of students for LL.B., LL.M. & other professional courses The Present Publication is the 2023 Edition and has been amended by the Finance Act 2023 and updated till April 2023. This book is authored by Neha Pathakji, with the following noteworthy features: • [Conceptual Foundation & Interpretation] of the Income-tax Law o Each Chapter Starts with an Introduction that outlines the foundational concepts • [Detailed Discussion on Legal Aspects of Income-tax Act Provisions] to appreciate tax controversies and disputes from a law perspective • [Landmark Rulings & Lucid Examples of Case Laws] has been incorporated into this book • [Lucid & Straightforward Style of Presentation] The provisions of the law are presented in a lucid and straightforward style • [Flow Charts] are provided in this book for ease in understanding complex provisions • [Zero-Error] The book follows the six-sigma approach to achieve the benchmark of 'zero-error' The detailed contents of the book are as follows: • Introduction to the Income-tax Act and Basic Concepts • Concept of Income • Interpretation of Taxing Statutes • Income Exempt from Tax • Residential Status of Scope of Total Income • Income from Salary • Income from House Property • Profits and Gains of Business or Profession • Capital Gains • Income from Other Sources • Income of Other Persons Included in Assessee's Total Income • Aggregation of Income, Set-off and Carry Forward of Losses • Deductions from Gross Total Income • Agriculture Income and Tax Liability • Charitable Trusts and Religious Institutions • Dividend • Double Taxation Relief • Assessment of Individual • Liability in Special Cases • Income-tax Authorities • Procedure for Assessment • Interest, Penalties, Offences and Prosecution • Appeals and Revisions • Advance Rulings • Deduction of Tax at Source • Advance Payment of Tax • Collection and Recovery of Tax • Refunds • Tax Implications of Business Re-organisation • Tax Planning, Tax Evasion and Tax Avoidance
Author: CA Ravi Chhawchharia Publisher: Taxmann Publications Private Limited ISBN: 9364550781 Category : Education Languages : en Pages : 55
Book Description
This book offers a comprehensive and practical application of Direct Tax Laws and International Tax, honing the reader's analytical skills. It perfectly balances an in-depth study and a summarized approach, presented in an explanatory and analytical manner. It is helpful for students preparing for CA-Final, CS-Professional, CMA-Final, M.Com/MBA/LL.B./LL.M, and other professional exams. The Present Publication is the 8th Edition for the CA Final | New Syllabus | May/Nov. 2025 Exam | A.Y. 2025-26). This book is authored by CA Ravi Chhawchharia, with the following noteworthy features: • [Complete Coverage] of the latest syllabus as prescribed by the ICAI • [Detailed Index] A well-organized index at the beginning helps students navigate through sections and other details • [Provisions] Comprehensive yet concise explanations of provisions, maintaining technical accuracy • [Judicial Decisions] Landmark/Prescribed by ICAI: Highlighted in bold and underlined, with case names provided before the facts and decisions • [Other Judicial Decisions] Only the ratio of the case is included, without requiring students to remember case names • [Practical Questions with Updated Solutions | Section-Based Questions] Included below the relevant provisions • [Multi-Section Questions] Placed at the end of each chapter in the 'Practical Questions' segment • [Amended & Updated] Incorporates the latest applicable provisions and amendments for A.Y. 2024-25, relevant for the November 2024 exams • [Judicial Decisions, Circulars & Notifications] Thoroughly covered • [Past Exam Solved Questions] Includes solved questions from past exams, including the CA-Final May 2024 paper The contents of this book are as follows: • Part I – Direct Tax Laws o Basic Concepts of Income Tax Laws and Tax Rates o Residential Status [Section 6] o Incomes which do not form part of Total Income [Section 10(1) to Section 10(50)] o Profits and Gains of Business or Profession [Section 28 to Section 44DB] o Capital Gains [Section 45 to Section 55A] o Income from Other Sources [Section 56 to Section 59] o Income Computation and Disclosure Standards o Tax on Conversion of Unaccounted Money [Section 56(2)(x), (viib); Section 94; Section 68 to 69D & Section 115BBE] o Income of other Persons, included in Assessee's Total Income (Clubbing of Income) [Section 60 to Section 65] o Set-off of Losses or Carry Forward and Set-off of Losses [Section 70 to Section 80] o Deduction from Gross Total Income [Chapter VI-A – Section 80C to Section 80U] o Deduction for Co-operative Societies [Sec.80P] o Deduction for Special Economic Zones [Section 10AA] o Taxation of Bonds [Circular No., 2/2002, dt. 15.02.2002] o Agriculture Income & its Tax Treatment [Section 2(1A) and Section 10(1)] o Taxation of Political Parties & Electoral Trust [Section13A and Section 13B] o Expenditure on Exempt Income [Section 14A and Rule 8D] o Taxation of Charitable/Religious Trusts [Section 11 to Section 13, Section 115BBC, Section 164, 164A, Section 10(23C)] o Taxation of Mutual Concerns [Section 44A and Section 28(iii)] o Application vs. Diversion of Income o Minimum Alternate Tax (MAT) [Chapter XII-B (Section 115JB and Section 115JAA)] o Taxation of Firms, LLP and AOP/BOI [Section 40(b), Section 10(2A), Section 167B, Section 86] o Alternate Minimum Tax (AMT) [Chapter XII-BA (Section 115JC – 115JEE) o Taxation of Buy-Back [Chapter XII-DA (Section 115QA to Section 115QC)] o Tax on Income of Securitisation Trust [Chapter XII-EA – Section 115TCA] o Taxation of Business Trusts (REITs, InvITs) and Alternative Investment Funds (AIF) [Chapter XII-FA – Section 115UA and Chapter XII-FB – Section 115UB] o Tonnage Taxation Scheme [Chapter XII-G – Section 115VA to Section 115VZC] o Assessment Procedures [Section 116, Section 124, Section 127, Section 129, Sections 139 to 154, Section 157A] o Appeals and Revisions [Sections 246A to 255, Sections 206A to 262 & Section 260B, Section 268A, Section 158A & Section 158AA, Sections 263 to 264B] o Survey, Search and Seizure [Section 119A, Sections 131 to 132B, Sections 133 to 135A, Sections 153A to 153D] o Provisions to Counteract Unethical Tax Practice [Chapter XXI – Secs. 270A to 275, Chapter XXII – Secs. 275A to 280D, Black Money Laws] o Dispute Resolution [Chapter XIX-AA – Secs. 245MA] o Direct Tax Vivad Se Vishwas Scheme, 2024 o Liability in Special Cases [Chapter XV – Section 159 to Section 179] o Assessment of HUF [Section 171] o Assessment of Firms and LLPs [Chapter XVI – Section 184 to Section 189] o Tax Deduction and Collection at Source [Chapters XVII-B and XVII-BB – Sections 192 to 206CCA] o Taxation of Digital Transactions [Equalisation Levy and Virtual Digital Assets] o Advance Tax [Chapter XVII-C – Section 207 to Section 211, Sections 218-219] o Collection and Recovery of Tax [Section 156 and Chapter XVII-D – Section 220 to Section 231] o Interest [Sections 201(A), 206C(7), Chapter XVII-F – Sections 234A to 234D, Section 244A] o Miscellaneous Topics, STT/CTT and IFSC [Sections 269SS, 269ST, 269SU, 269T, Section 139A, Section 139AA, Sections 281, 281B, 282, 282A, 285BA, 285BB, 288, 293C, 293D, 115BBF, 115BBG] o Tax Audit and Ethical Compliances o Tax Planning, Tax Avoidance and Tax Evasion (Including GAAR) • Part II – International Taxation o Tax Incidence in India [Section 6(3), Sections 7 to 9A, Section 115JH, Section 285 and Section 285A] o Taxation of Non-Residents [Section 115A to Section 115AD, Section 115BBA and Chapter XIIA – Sections 115C to 115-I] o Double Taxation Relief (DTAA) [Chapter IX – Sections 90, 90A and 91] o Transfer Pricing [Chapter X – Section 92, Section 92F, Sections 93, 94A, 94B, 114C and Section 286] o Advance Rulings [Chapter XIX-B – Section 245N to Section 245U] o Overview of Model Tax Conventions o Application and Interpretation of Tax Treaties o Fundamentals of Base Erosion and Profit Shifting (BEPS) o Latest Developments in International Taxation
Author: Daksha Baxi Publisher: Taxmann Publications Private Limited ISBN: 9357782400 Category : Law Languages : en Pages : 44
Book Description
This book is India's first 'ready reckoner' with a specific focus on international taxation & taxation of cross-border transactions. It covers the entire spectrum of topics, which are as follows: • Basic provisions of the scheme of taxation in India • Residence in India • Role of Double Taxation Avoidance Agreements (DTAA) • Interaction of DTAA with the Income-tax Act • How to read a DTAA? • How to determine eligibility for DTAA? • How to resolve the conflict between a DTAA & Income-tax Act? It is an essential handbook for anyone who is dealing with cross-border transactions, including: • Payments made to non-residents • Transactions with non-residents • Digital transactions • Withholding tax obligation obligations of residents The Present Publication is the 1st Edition and has been amended by the Finance Act 2023. This book has been authored by CA Daksha Baxi & Adv. Surajkumar Shetty with the following noteworthy features: • [Exhaustive Coverage] of the tax implications on cross-border transactions • [Evaluating the Taxability] using the following: o Income-tax Act o Double Taxation Avoidance Agreement o Reference to Rules, Forms, Circulars, etc. o Reference to Case Laws • [Authors' Notes] are given for the following: o How should an advisor approach the transaction? o What investigations should be made to apply the law and principles of the Income-tax Act & Double Taxation Avoidance Agreement? • [Conceptual Analysis in Simplified Language with Examples & Case Laws] for the following 'noted' topics, among others: o Place of Effective Management o Permanent Establishment o Business Connection o Foreign Portfolio Investors o Investment Funds & their Investors § Alternative Investment Funds (AIFs) § Infrastructure Investment Funds (InvITs) § Real Estate Investment Trusts (REITs) § Securitisation Trust • [Covering Provisions relating to Litigation Proceedings] under the following: o Income-tax Act o Mutual Agreement Procedure (MAP) under the Double Taxation Avoidance Agreement o Authority for Advance Ruling (AAR) Process o Equalisation Levy o Transfer Pricing Provisions o General Anti Avoidance Rules (GAAR) o Special Provisions for International Financial Services Centres (IFSC) • [Illustrations/Examples, Practical & Comprehensive Case Studies] are given to provide insights into the finer nuances of cross-border transactions The detailed contents of the book are as follows: • Tax System for Non-Residents in India – An Overview • Tax Treaties • Setting Up a Business in India • Classification of Income • Determining Eligibility to Claim Benefits of DTAA • Taxation of Rental Income • Taxation of Business Income • Taxation of Dividend Income • Taxation of Interest Income • Taxation of Royalty Income • Taxation of Income from Fees for Technical Services • Taxation of Capital Gains • Taxation of Employment Income • Taxation of Non-Resident Indian • Taxation of Foreign Portfolio Investors • Taxation of AIFs, REITs, InvITs, Securitisation Trust • Transactions Attracting Transfer Pricing Regulations • Business Reorganisations • Discontinuance of Business and Dissolution of Indian Company • Foreign Tax Credit • Making Payments to NRs & Obtaining Lower Withholding Certificate • Assessments, Appeals and Dispute Resolution • General Anti-Avoidance Rules • Miscellaneous • Case Study to Determine Taxability of NR, under the IT Act & DTAA
Author: Taxmann Publisher: Taxmann Publications Private Limited ISBN: Category : Law Languages : en Pages : 30
Book Description
Considering the success of the prior scheme and the increasing backlog of appeals at the CIT(A) level, the Government has introduced the Direct Tax Vivad se Vishwas Scheme, 2024 ('Scheme' or 'DTVVS') through the Finance (No. 2) Act, 2024. The DTVVS provisions are outlined in Sections 88 to 99 of the Finance (No. 2) Act, 2024. This article comprehensively answers all pertinent questions regarding the Scheme's FAQs, offering insights based on its current framework and the clarifications provided by the CBDT for similar schemes from preceding years. Key FAQs discussed include: ‣ What are the salient features of the Scheme? ‣ Can taxpayers opt for this Scheme if they have availed of a similar scheme announced in earlier years? ‣ How does DTVVS 2024 differ from DTVVS 2020? ‣ What are the consequences for an assessee who declares to settle disputed tax arrears under the Scheme? ‣ Does the Scheme offer immunity from prosecution to the declarant? ‣ Who is ineligible to make a declaration under the Scheme? ‣ Is the bar on making a declaration applicable solely to the assessment year for which prosecution has been initiated?
Author: CA CS CMA (Dr.) Priyanka Saxena Publisher: Taxmann Publications Private Limited ISBN: 9357785965 Category : Education Languages : en Pages : 18
Book Description
This book is specifically designed to meet the requirements of the Intermediate Level Cost & Management Accountancy Examination. It includes past exam questions and detailed answers aligned with the latest ICMAI syllabus. The Present Publication is the 2nd Edition for the CMA Intermediate | New Syllabus | Dec. 2024/June 2025 Exams. This book is authored by CA CS CMA (Dr.) Priyanka Saxena, with the following noteworthy features: • [Strict Adherence to the New ICMAI Syllabus] Ensuring complete alignment with the latest requirements • [Comprehensive Coverage] o Past Exam Questions – Includes questions from the CMA-Intermediate | June 2024 Exam • [Introduction to Each Chapter] is included in the book covering the following: o Definitions o Concepts o Formulas • [Most Updated & Amended] This book is updated & amended as per the following: o Income Tax Answers are Modified as per A.Y. 2024-25 o GST & Customs Answers are Modified as per the Latest GST & Customs Laws • [Tabular Summaries] Provided at the beginning of each chapter for quick reference • [Marks Distribution] Detailed chapter-wise distribution from June 2018 onwards • [Previous Exam Trend Analysis] From June 2023 • [ICMAI Study-Material Comparison] Provided module-wise for a comprehensive understanding The contents of this book are as follows: • Section A – Direct Taxation (DT) o Overview of Income Tax o Residential Status o Incomes Which Do Not Form Part of Total Income o Income from Salary o Income from House Property o Income from Profits and Gains of Business and Profession o Income from Capital Gains o Income from Other Sources o Clubbing of Income o Set-off and Carry Forward of Losses o Deductions, Rebate & Relief o Advance Tax o TDS & TCS o Filing of Return of Income o Self-Assessment & Intimation • Section B – Indirect Taxation (IDT) o Introduction to GST o Concept of Supply o Exemptions from GST o Composition Scheme o Time of Supply o Valuation under GST o Input Tax Credit o Registration under GST o Tax Invoice o E-Way Bill o Returns o Types of Customs Duties o Valuation under Custom
Author: Taxmann Publisher: Taxmann Publications Private Limited ISBN: Category : Law Languages : en Pages : 33
Book Description
The year 2023 witnessed a plethora of pivotal Direct Tax judgments that are essential for taxpayers and revenue authorities to note. This article provides an analytical overview of the year's top 20 Direct Tax case laws, as reported on Taxmann.com | Research. Each case law in this compilation is accompanied by a brief three-line digest and comprehensive headnotes, meticulously crafted and scrutinized by a team of expert professionals. We aim to highlight the core issue and the principle of the decision (ratio decidendi) in each case while seamlessly integrating it with all related records. This approach ensures a comprehensive understanding of each judgment for our readers.
Author: Mayank Mohanka Publisher: Taxmann Publications Private Limited ISBN: 935778005X Category : Law Languages : en Pages : 35
Book Description
This book is a ready reckoner & go-to-guide for the assessee and tax practitioners to understand the practicalities and nuances of the following in an effective, qualitative, and timely manner: • Faceless Assessments u/s 144B of the Income-tax Act as amended by the Finance Acts 2022 & 2023 • Newly substituted Faceless Appeal Scheme, 2021 legislated w.e.f. 28.12.2021 • Faceless Penalty Scheme, 2021 incorporated w.e.f. 12.01.2021 & substituted with Faceless Penalty (Amendment) Scheme, 2022 • Newly Amended Reassessment Regime u/s 147-15, conducted in a faceless manner via faceless assessment • The newly inserted legislative faceless schemes are also explained: o e-Assessment of Income Escaping Assessment Scheme, 2022 u/s 151A o Faceless Jurisdiction of Income-tax Authorities Scheme, 2022 u/s 130 o e-Verification Scheme, 2021 u/s 135A o e-Advance Rulings Scheme, 2022 & e-Settlement Scheme, 2021 u/s 245D The Present Publication is the 6th Edition and has been amended up to 8th April 2023. This book is authored by Mayank Mohanka, with the following noteworthy features: • [Lucid Explanation with Illustrative Tables, Infographics, Visual & Real-time Scrutiny Windows] for the Faceless Assessment/Reassessment, Faceless Appeals Scheme & Faceless Penalty Proceedings • [30+ Real-time Practical Case Studies] for the following issues: o Disallowance on Account of Related Party Transactions o Additions on account of Variation between IND AS Adjustments & ICDS o Disallowance in respect of Exempt Income u/s 14A & Rule 8D o Case Study on Reply to New Reassessment Regime Notice o Case Studies on Section 143(1) Intimations o Disallowance of Foreign Tax Credit to Residents on Account of Non/Delayed Filing of Form 67 o Disallowance of Unexplained Expenditure o Disallowance of Deduction to Export-Oriented Units in Special Economic Zones o Disallowance of Bad Debts o Additions Made on Estimated Income Basis o Additions made in the hands of Group Housing Societies o Addition on account of HSBC Foreign Bank Account o Reassessment on account of Information from another IT Authority o Admission of Additional Evidence under Rule 46A o Cash Deposits out of Earlier Cash Withdrawals o Addition on account of considering Rental Business Income as Income from House Property o Appeal against Revisionary Order u/s 263 o Appeal against TDS Order u/s 201/201(1A) o Appeal against Rectification Order u/s 154 o Cash Deposits during Demonetisation o Valuation of Shares u/s 56(2)(x) o Share Capital u/s 68 o Share Premium u/s 56(2)(viib) o LTCG on Penny Stocks o Disallowance of Pre-commencement Business Expenditure o Taxability of Compensation received under RFCTLAAR Act, 2013 o Revenue Recognition & Expenditure Booking in Real Estate Business o Bogus Purchases o Seized Diary o AIR/STR information o Reply to Penalty Notice • [Practical Guide] for the following topics: o [Actual Conduct of Proceedings] for Faceless Assessments, Faceless Appeals & Faceless Penalty, demonstrated in the following manner: § Step-by-Step § Through the Real-time e-Proceedings window o [e-Filing & e-Responses] of rectification applications u/s 154 & outstanding income tax demands respectively • [Deciphering Critical & Legislative Issues] on the Faceless Taxation Regime, such as: o What would constitute a valid issuance & service of a faceless income tax notice? o Whether the omission of section 144B(9) makes faceless assessments conducted in violation of the principle of natural justice immune? o Whether the NaFAC be considered a lawful substitute for recording satisfaction by jurisdictional AO? o What is the validity of a frequent transfer of faceless assessments & penalty cases from faceless hierarchy to jurisdictional AO? o What is the legality of fixing the maximum time limit for filing all the e-responses by the assessee under the e-proceedings functionality under faceless assessments? o What is the validity of exercising revisionary powers by an individual jurisdictional CIT(Appeal) u/s 263/264 over an order passed by a dynamic jurisdiction in the faceless hierarchy? o What are adequate safeguards for avoiding high-pitched assessments in the faceless regime? • [Frequently Asked Questions/FAQs] on the Faceless Taxation Regime • [International Best Practices] in Tax Administration & Indian Tax Administration • [Latest CBDT's Circulars, Notifications & Press Releases] on the Faceless Taxation Regime updated till 08.04.2023 The detailed contents of this book are as follows: • Faceless Taxation Regime: Our Own Generative Pre-trained Transformer (GPT) • Amended Faceless Regime in Finance Act 2022 • Practical Guide to e-Proceedings • Guidelines for Compulsory Selection of Cases for Complete Scrutiny in FY 2022-23 in Faceless Regime • Practical Case Study on Disallowance of Related Party Transactions in Faceless Assessment • Practical Case Study on Ind AS Adjustments in Computation of Income in Faceless Assessment • Practical Case Study on Disallowance u/s 14A & Rule 8D in Faceless Assessment • Faceless Assessment Under New Regime • Practical Case Study on Faceless Reassessment under New Regime • Practical Case Study on Addition of Receipts of a Residents' Welfare Society in Faceless Assessments • Practical Case Study on Denial of Foreign Tax Credit in Faceless Assessment • Practical Case Study on Addition of Share Capital & Share Premium Receipts in Faceless Assessments • Practical Case Study on Addition of Long-Term Capital Gain on Penny Stock • Practical Case Study on Disallowance of Exemption u/s 10AA in Faceless Assessment • Practical Case Study on Disallowance of Pre-commencement Business Expenditure in Faceless Assessments • Practical Case Study on Addition of Compensation Received under RFCTLARR Act, 2013 in Faceless Assessment • Practical Case Study on Revenue Recognition & Expenditure Booking in Real Estate Business in Faceless Assessments • Practical Case Study on Disallowance of Purchases treating them as Bogus • Practical Case Study on Addition Based on Seized Diary • Practical Case Study on Addition based upon Annual Information Return (AIR) • Practical Case Study on Cash Deposit during Demonetisation • Practical Case Study on Valuation of Shares u/s 56(2) • Decoding Lesser Known Nuances of Faceless Assessment • International Best Practices & Indian Tax Administration • FAQs on Faceless Regime • Standard Operating Procedure (SOP) for Faceless Assessment Proceedings u/s 144B of the Income-tax Act • Miscellaneous Faceless Scheme under the Income-tax Act • Faceless Appeals in its new Avatar • Decoding Faceless Appeals Scheme 2021 • Practical Guide to Faceless Appeals • Practical Case Study on Faceless Appeals on Disallowance of Employees' Contribution to PF & ESI • Practical Case Study on Faceless Appeals: Addition in Respect of Foreign Bank Account • Practical Case Study on Addition Based on Information Received from Another IT Authority • Practical Case Study on Faceless Appeals: Admission of Additional Evidence • Practical Case Study on Faceless Appeals: Cash Deposits during Demonetisation • Practical Case Study on Faceless Appeals: AOs Treatment of Business Rental Income as Income from House Property • Practical Case Study on Appeal before ITAT: Challenge to Revisionary Order u/s 263 • Practical Case Study on Appeal Representation in Respect of Section 201 Order • Practical Case Study on Faceless Appeals: Challenge to Rectification Order u/s 154 • Practical Case Study on Faceless Appeals on Addition of Unexplained Expenditure & Disallowance of Bad Debts • Decoding the New Rules of Penalty Shoot-out: Faceless Penalty Scheme • Practical Case Study on Faceless Penalty u/s 271B • Practical Guide to E-Filing of Rectification Application & Response to Outstanding Demand • Time to Make Artificial Intelligence Intelligent & Machine Learning Learn • Analysis of High Court Judgements on Faceless Assessments & Lessons Learnt
Author: Jonathan Schwarz Publisher: Kluwer Law International B.V. ISBN: 9403526319 Category : Law Languages : en Pages : 870
Book Description
Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.
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