The author is Gurasis Singh Grover , a Fifth Year Student from Indian Institute of Management (IIM) Rohtak. Abstract: The taxation of slump sales is not amenable to the general computation of capital gains under Section 45 of Income Tax Act 1961 (“the Act”). Hence, Section 50B introduced a special mechanism for computation. Finance Act 2021 amended Section 50B of the Act to widen the scope of slump sales. Subsequently a CBDT Notification dated 24 May 2021 inserted Rule 11UAE

The Supreme Court recently confirmed the Delhi High Court’s judgment which held that Hyatt had a permanent establishment under Article 5 of the Indo-UAE DTAA, thereby denying them benefits under the Indo-UAE DTAA. Relying on the two tests laid down in the Formula One World Championship Ltd v. Commissioner of Income Tax, the court held that Hyatt held substantive control over AHL’s operations. This article argues that the Court overlooked factual differences and misapplied the

The author is Utkarsh Shukla, a Second Year Student from Rajiv Gandhi National University of Law . Abstract: The article examines the...