Shreshth Nigam and Ram Sundar Singh Akela I. INTRODUCTION By putting his trust and capital into a state-recognised instrument, a citizen does so upon the basis of a legal promise that the conditions under which he invested will be respected during its existence. This promise is what has been threatened by the recent announcement of […]
Category: Taxation
Harshita Dhinwa and Ram Sundar Singh Akela Introduction The Tax Residency Certificate was never a complete answer to the question of treaty entitlement on a proper reading of a treaty text and international law. It functioned primarily as a proof of jurisdiction, but over time, institutional practice elevated it to a substantial safeguard, which was […]
Qazi Ahmad Introduction The Supreme Court recently held that the State can withdraw earlier granted Tax exemptions to industries in public interest in State of Maharashtra v. Reliance Industries Ltd. However, the case is being treated as a minor issue of a decision to withdraw a Tax exemption of electricity-duty. However, such a reading diminishes […]
Pushpendra and Moazzam Hussain Introduction The distinction between capital and revenue expenditure is among the most enduring fault lines in Indian income-tax jurisprudence. This uncertainty becomes particularly acute in the context of non-compete fee which is a standard feature of corporate transactions. Non-compete covenants are commercially pivotal as they preserve deal value by preventing the […]
Keshav Maheshwari Introduction: A Crisis of Confidence in a Cashless Revolution India’s Unified Payments Interface (UPI) stands as a monumental achievement in public digital infrastructure, a system that has dramatically lowered transaction costs and brought millions into the formal financial fold. However, a recent and unforeseen development threatens the very trust upon which this revolution […]
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