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Bhawna Lakhina

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Associate in the Taxation Practice at the Delhi - NCR office of Cyril Amarchand Mangaldas. Bhawna can be reached at bhawna.lakhina@cyrilshroff.com

Delhi ITAT delivers one of the first decisions dealing with Principal Purpose Test

The principal purpose test (“PPT”) has been introduced into the Indian double taxation avoidance agreement (“DTAA”) lexicon through the base erosion and profit shifting (“BEPS”) project of the Organisation for Economic Cooperation and Development (“OECD”) to dissuade sophisticated taxpayers from entering into transactions aimed at tax avoidance. The requisite amendments to the DTAAs have been made via multilateral instruments (“MLIs”).Continue Reading Delhi ITAT delivers one of the first decisions dealing with Principal Purpose Test

AMT: Does It Impose Additional Taxes Under Income Tax Bill, 2025?

Background

The Alternate Minimum Tax (“AMT”) has its genesis in the Minimum Alternate Tax (“MAT”), which was introduced to ensure that taxes were paid by even those companies that intended to avoid payment of taxes by engaging in ingenuous tax planning methods despite having earned significant amount of book profits. These companies, called “zero-tax companies”, while reporting significant book profits, paid minimal or no income tax by leveraging various exemptions and deductions available under the Income Tax Act, 1961 (“IT Act”). Continue Reading AMT: Does It Impose Additional Taxes Under Income Tax Bill, 2025?