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Taxation
Principal Purpose Test in focus: When Commercial Reality Trumps Formal Presence
In this article, a Mumbai ITAT ruling is examined to show how commercial substance and genuine intent can outweigh formal presence when claiming treaty benefits.
Published with permission of Ameet Baid, Chandandeep Kaur & Ishmeet Kaur Jan 29, 2026
76 AERIAL
Article Taxation
Is Supply Chain Management a mere Commercial Issue?
In this article, supply chain management is examined beyond cost and logistics, highlighting how tax-efficient structuring plays a strategic role in long-term value creation.
Published with permission of Ameet Baid, Chandandeep Kaur & Ishmeet Kaur Jan 6, 2026
19 ME
Article Taxation
Effective Connected’ and ‘Attribution’- Are They the Same? A Myth
In this article, the fine distinction between ‘effectively connected’ and ‘attributable’ income is explored, highlighting how it defines the taxability of cross-border profits linked to a Permanent Establishment. It explains why recognising this difference is vital for accurate profit attribution, treaty interpretation, and reducing international tax disputes.
Published with permission of Kunal Arora & Aakanksha Bansal Nov 10, 2025
01 BUIDINGS
The Bottom Line
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Regulatory Compliance Taxation
Income Tax Act 2025: Key Changes Businesses Must Know
India’s Income-tax Act, 2025, effective April 1, 2026, is more than a statutory update. it’s an opportunity for businesses to simplify, align, and future-proof their tax positions. While the law brings clarity, its true impact will depend on how organizations adapt with stronger structures, sharper documentation, and proactive planning.
Published with permission of Sunil Arora - ASA | Bikramjit Bedi - ASA | Pankaj Aneja - ASA Sep 24, 2025
Income Tax bill
Regulatory Compliance Taxation
To Guarantee or not to Guarantee - That is the question
GST, launched mid-stream, is now 7 years old. Like any voyage, calm seas give way to storms. A new storm: taxing corporate guarantees from parent to subsidiary.
Sundeep Gupta Aug 27, 2025
97 AR
Regulatory Compliance Taxation Media
Online Gaming & The Game of Tax
With the advent of technology and quantum leaps in internet bandwidth infrastructure in India, while gaming on the ground continued to enthrall the populace, digital gaming started coming of age.
Sundeep Gupta Aug 27, 2025
2024 Online Gaming
Regulatory Compliance Taxation
Navigating UK VAT Accounting
Understanding and managing Value Added Tax (VAT) can sometimes feel like deciphering a complex puzzle.
Manuj Sharma, Simran Nayal, Chhavi Goyal Aug 27, 2025
2024 Navigating UK VAT Accounting
Regulatory Compliance Taxation Aerospace & Defence
Flying High, Taxing Higher
In the intricate tapestry of modern economies, few industries hold as significant a role as the aviation sector.
Lakshay Chhabra Sundeep Gupta Aug 27, 2025
33 MT
Regulatory Compliance Taxation
Identical Fact Matrix Guide
Taxpayers citing favorable precedents from similar subsidiaries must prove identical facts and independently substantiate their claim with documentation.
Karthik SS, Rakesh K S Aug 26, 2025
Default image for insights
Regulatory Compliance Taxation
ISD Applicability from April 01, 2025: Comprehensive Guide
The Goods and Services Tax (‘GST’) regime in India, implemented on July 1, 2017, has ushered in a transformative era in India's tax landscape.
Sundeep Gupta Apr 17, 2025
2025 ISD Applicability 2025
India Advisory Business Advisory Taxation
Incentives for SEZ Units in India
India's SEZs are duty-free zones boosting exports & FDI. Created in 2000, formalized in 2005/2006, they offer a competitive export-import climate.
Shyam Radhakrishnan Himanshu Srivastava Nov 6, 2024
2024 Incentives For Sez Units In India
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