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Tribunal holds that proceedings under Black Money Act jurisdictionally defective where the assets under an offshore trust structure were held to be not subject to Wealth Tax in the hands of the assessee Yashovardhan Birla, the assess
Aurtus Direct Tax Alert Shailendra padhiyar Aurtus Direct Tax Alert Shailendra padhiyar

Tribunal holds that proceedings under Black Money Act jurisdictionally defective where the assets under an offshore trust structure were held to be not subject to Wealth Tax in the hands of the assessee

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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.
Aurtus Direct Tax Alert Shailendra padhiyar Aurtus Direct Tax Alert Shailendra padhiyar

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.

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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 19
Aurtus Direct Tax Alert Shailendra padhiyar Aurtus Direct Tax Alert Shailendra padhiyar

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.

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