In a significant policy development, CBDT has issued a notification, amending Rule 128 of the Income-tax Rules, 2026 pertaining to applicability of GAAR, with effect from 1 April 2026. Rule 128(1)(d) grandfathered pre-April 2017 investments from GAAR. However, Rule 128(2) provided GAAR applies to any arrangement yielding a tax benefit on or after 1 April […]
Background of the case In a significant ruling, the Mumbai Income Tax Appellate Tribunal (‘ITAT’), in the case of Fairbridge Capital (Mauritius) Limited, has delivered an important judgment clarifying the scope and applicability of Section 56(2)(x) of the Income-tax Act, 1961 (‘the Act’) in the context of conversion of Optionally Convertible Cumulative Redeemable Preference Shares […]
Background of the case In a recent ruling, the Supreme Court (“The Hon’ble Court”) in the case of M/s Jindal Equipment Consultancy Services Ltd (“the assessee” or “the Company”) adjudicated a batch of appeals concerning the taxability of shares received by shareholders upon amalgamation, specifically where the shares of the amalgamating company were alleged to […]
Background of the case In a recent ruling, the Supreme Court (‘SC’), in the case of Jupiter Capital Pvt Ltd (‘Company’ or ‘assessee’), examined the tax consequences of capital reduction and its treatment under the provisions of the Income Tax Act, 1961 (‘IT Act’), particularly Section 2(47) concerning the definition of ‘transfer’. The landmark judgement […]
Overview The Union Budget for FY 2026-27, presented by the Hon’ble Finance Minister, Ms. Nirmala Sitharaman, in Parliament on 1 February 2026, was positioned as a continuation of the Government’s emphasis on economic stability, fiscal discipline, and long-term growth. Anchored around three guiding ‘Kartavya’ pillars, the Budget signals a clear intent to build a competitive, […]
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