Asia: Tax

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Article
CBDT Clarifies The Applicability Of GAAR Grandfathering On Income From Transfer Of Investments Acquired Prior To 1 April 2017
The Central Board of Direct Taxes (CBDT) has issued a notification dated 31 March 2026 (Notification), providing a significant clarification on the non-applicability of General Anti-Avoidance Rules (GAAR) with respect to income arising from the transfer of an investment that was made prior to 1 April 2017. This development seeks to resolve the ambiguity that arose pursuant to the judgment of the Hon’ble Supreme Court (SC) in the case of Tiger Global International II Holdings.
India Tax
KC
Khaitan & Co LLP
Article
Supreme Court Clarifies Taxability Of Share Substitution In Amalgamations: Role Of Commercial Realisability
In recent years, corporate India has witnessed an increasing number of amalgamations, group consolidations, and share-swap mergers driven by restructuring, capital efficiency, and regulatory considerations. Such transactions are often designed on the assumption that share-for-share exchanges are tax neutral, particularly where no cash changes hands.
India Tax
HS
Hammurabi & Solomon
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Related Country Guides

TD
Tax Disputes
CT
Corporate Tax

Sales Taxes: VAT, GST

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Transfer Pricing

Article
India Transfer Pricing & Permanent Establishment Disputes: Characterisation, Profit Attribution And Litigation Strategy
Within most multinational groups, transfer pricing is still perceived primarily as a technical compliance function. It is frequently treated as a year-end margin exercise — a benchmarking study intended to ensure that operating profit falls within a statistical range. Boards often view it as a documentation issue, while finance teams approach it as a provisioning variable.
India Tax
R & D Law Chambers LLP
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Tax Treaties

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Inheritance Tax

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Latest Videos

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