Ahmedabad bench of Tribunal holds that the excess of net assets taken over by the amalgamated company against issue of its shares at face value towards consideration for amalgamation cannot be taxed under section 56(2)(viib) of the Act.

Payment to non-resident software manufacturers/suppliers for sale of software under end user license agreements/distribution agreements does not qualify as ‘royalties’ under DTAA and not liable for withholding taxes under section 195.

Faceless Penalty Scheme

Mumbai bench of Tribunal holds that assets held under an offshore trust structure not subject to wealth tax in the hands of the beneficiaries in India.

Madras HC ruling on contribution of funds received by trust