Income Tax

Background In a recent ruling, the Delhi Income-Tax Appellate Tribunal (“The Tribunal”) adjudicated the case of Rajesh Kumar Sharma (“the assessee”) arising from the order passed by the CIT(A)/NFAC, Delhi dated 03.08.2023 for Assessment Year 2016–17. The assessment was framed under Section 147 of the Income-tax Act, 1961 (“the Act”). The dispute pertains to the […]

Background In a recent ruling, the Mumbai Income-tax Appellate Tribunal (“the Tribunal”), in the case of Atyant Capital India Fund-I (“the Company” or “the Assessee”), examined the tax treatment of long-term capital gains and losses arising from investments by a Foreign Portfolio Investor (FPI) resident in Mauritius. The central issue relates to the interplay between […]

Background In a recent ruling, the Chennai Income Tax Appellate Tribunal (“ITAT” or “Tribunal”), in the matter of M/s. Aathmika Holdings Pvt. Ltd. v. DCIT (“Assessee” or “Company”), examined the scope of Section 56(2)(x) of the Income-tax Act, 1961 (“IT Act”), specifically regarding the determination of Fair Market Value (FMV) of unlisted shares acquired by […]

Background In a recent ruling, the Delhi High Court (“The Court”), in the case of Equity Intelligence AIF Trust, examined the taxability of Category III AIFs (Alternative Investment Funds) under Section 164 of the Income Tax Act, 1961 (“IT Act”). The key issue pertained to whether the absence of investor names or their beneficial interests […]

Background In a recent ruling, the Mumbai Income-tax Appellate Tribunal (“the Tribunal” or “the ITAT”), in the case of ISC Specialty Chemicals LLP, examined the tax implications of converting a private limited company into a Limited Liability Partnership (LLP) under the provisions of the Income-tax Act, 1961 (“IT Act”). The Tribunal analysed whether the statutory […]