Taxation of Income from Transfer of Intangible Assets between Non-Residents

[The following guest post is contributed by Shailendera Singh, who is a lawyer practising in Delhi. He can be reached at [email protected]] A judgment of the Delhi High Court rendered on July 25, 2016 in CUB Pty Limited (Formerly Known as Foster’s Australia Ltd) v. Union of India has held that the situs of an intangible property is where the owner of the property resides, and a transfer...

The Direct Tax Proposals in Budget 2012

Unsurprisingly, the retrospective amendment proposed to be made to sections 2 and 9 of the Income Tax Act has dominated analysis of the direct tax proposals in the budget. There is no doubt that these amendments, and particularly the validation clause in cl 113 of the Finance Bill, may be vulnerable to a constitutional challenge, and this is a subject we will discuss in more detail. Budget 2012...

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