...tune of 300 to 400% of its initial corpus amount clearly indicate that it is not a normal business practice but a deliberate carefully conceived tax planning strategy on a long-term basis...provisions and the outlook of Department itself based on such legal provisions permit the assessee to have the tax planning of this nature, and the course of action taken by the assessee is permissible...as to whether it was appropriate on business expediency for the assessee to incur such an expenditure or not. If the transaction is otherwise valid in law and is a part of tax planning, merely because...

...• Tax advice regarding strategy and tax planning.• Legal assistance on property and legal structure issues as well as related to business acquisitions and disposals.5...1. This is an appeal by Revenue against the order of the Commissioner of Income Tax (Appeals)-3, Hyderabad, dated 06-02-2015 for the A.Y. 2011–12. The issue in this appeal is on the...an agreement dated 01.01.2008, that the appellant had also deducted tax on the management fees. The CIT(A) held that the assessee had incurred such cost in view of the agreement with its overseas...

...tune of 300 to 400% of its initial corpus amount clearly indicate that it is not a normal business practice but a deliberate carefully conceived tax planning strategy on a long-term basis...provisions and the outlook of Department itself based on such legal provisions permit the assessee to have the tax planning of this nature, and the course of action taken by the assessee is permissible...as to whether it was appropriate on business expediency for the assessee to incur such an expenditure or not. If the transaction is otherwise valid in law and is a part of tax planning, merely because...

...Stock Market Advisory, Intraday Tips, Stock Trading Tips, Share Market Tips, Super Power Tips, Growing Wealth, Tax Planning, Investment Planning and Strategy, etc. iv. As part...firm that provides tips for the stock and commodity markets. b. Fingravy offers services in the area of tax planning and investment planning and strategy for consideration. 16.../- 11. Further, as per the website of Fingravy, it was observed that they charge advisory fee which ranges from: Initial planning Fee Monthly Retainer Fee Rs 50,000- Rs 3,00,000 Rs. 50,000- Rs...

...deliberately filed inaccurate particulars of income and has clearly indulged in tax evasion. It is a well-planned strategy and the conduct of the appellant categorically reflects the intent and planning...S. Rifaur Rahman, A.M.:— This is an appeal of the assessee directed against the order of the learned Commissioner of Income-tax(A) - III, Hyderabad, dated 10/09/2013, for AY 2006-07...of tax evasion. It is therefore a fit case for levy of penalty and the same which has been levied by the assessing officer is hereby confirmed.”.7. Aggrieved by the action of the CIT(A...

...production management and planning and equitable quality assurance strategy, quality development and is liable to tax? 9. The aforesaid substantial questions of law arose for...) Co-ordination of global production management and planning and (d) global quality assurance and strategy and policy development. 2. With the permission of the Reserve Bank of India...N. Kumar, J. 1. The petitioner is a company incorporated in the United State of America (USA) and is a tax resident of the USA and it is a multinational company engaged...

...) proactively reviews existing and planned operations to identify relevant tax planning possibilities, to ...the Appellant to Strategy and applicable rules and regulations in take a decision on a particular tax Policy the countries where ISS operates. position and thereby comply with the Group Tax is... IN THE INCOME TAX APPELLATE TRIBUNAL "H" BENCH, MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER...

..., Intraday Tips, Stock Trading Tips, Share Market Tips, Super Power Tips, Growing Wealth, Tax Planning, Investment Planning and Strategy, etc. iv. As part of our services...offers services in the area of investment planning and strategy for consideration. I note that at one place, the website of Noticee no. 1 also mentions the words ‘Tax Planning’, but after perusal of the...entire sentence, it is evident that the phrase ‘tax planning’ is mentioned merely as a running reference, without any substantive elaboration. The overall content of the website of Noticee no. 1 is...

...Wealth, Tax Planning, Investment Planning and Strategy, etc. Page 6 of 21 iv. As part of our...that Noticee no. 1 is an investment advisory firm that provides tips for the stock and commodity markets for consideration, and offers services in the area of investment planning and strategy for...consideration. I note that at one place, the website of Noticee no. 1 also mentions the words 'Tax Planning', but after perusal of the entire sentence, it is evident that the phrase 'tax planning' is...

...to take on funding risks which an independent borrower would avoid. Factors such as group policy, strategy, and tax planning will sit alongside commercial considerations...." INTM542012 provides...a 2008 IBFD publication "International Tax Planning and Prevention of Abuse" (by Dr Luc De Broe : ISBN 978- ITA No. 2006/Bang/2017, IT(TP)A Nos. 63 & 84/Bang/2015, 599, 2060 & 2178...: (1985) 154 ITR 148 (SC), which, inter alia, holds that "colourable devices cannot be part of tax planning and it is wrong to encourage or entertain the...

...to take on funding risks which an independent borrower would avoid. Factors such as group policy, strategy, and tax planning will sit alongside commercial considerations...." INTM542012 provides...a 2008 IBFD publication "International Tax Planning and Prevention of Abuse" (by Dr Luc De Broe : ISBN 978- ITA No. 2006/Bang/2017, IT(TP)A Nos. 63 & 84/Bang/2015, 599, 2060 & 2178...: (1985) 154 ITR 148 (SC), which, inter alia, holds that "colourable devices cannot be part of tax planning and it is wrong to encourage or entertain the...

...to take on funding risks which an independent borrower would avoid. Factors such as group policy, strategy, and tax planning will sit alongside commercial considerations...." INTM542012 provides...a 2008 IBFD publication "International Tax Planning and Prevention of Abuse" (by Dr Luc De Broe : ISBN 978- ITA No. 2006/Bang/2017, IT(TP)A Nos. 63 & 84/Bang/2015, 599, 2060 & 2178...: (1985) 154 ITR 148 (SC), which, inter alia, holds that "colourable devices cannot be part of tax planning and it is wrong to encourage or entertain the...

...to be removed, civic and social amenities to be provided etc. All these require a balanced use of available land. It is with that object that the Mysore Town and Country Planning Act was enacted in...(4) of the Karnataka Town and Country Planning Act and take all consequential action in accordance with law.5. Shri Cooper, learned counsel for the appellants urged that...necessary to refer to the relevant statutory provisions.7. In 1961 the Bangalore Metropolitan Planning Board was formed. The Board prepared an Outline Development Plan (for...

...reduce the estate tax. In some situations it may be advisable to pay the tax in advance to reduce the size of the estate.In many instances, however, an estate planning strategy is to give the maxim...3,01,73,975/- to the returned income by invoking Section 68 of the Income Tax Act.1.2 The Learned Assessing Officer failed to appreciate that your appellant had completely discharged the burden...relying upon a foreign tax law for justifying the addition in the case of resident Indian. The Learned Assessing Officer failed to appreciate that payment or non payment of taxes on the foreign gift is of...

...) of the Gujarat Town Planning and Urban Development Act, 1976 (hereinafter referred to as the Town Planning Act) are ultra vires and the impugned regulations purported to have been made under the Town...Planning Act are ultra vires Articles 14, 19 and 21 of the Constitution and the said regulations are also ultra vires the Town Planning Act itself. The writ petitioners also made a prayer before the...) The levy of development fee is ultra vires as the same does not fall under Section 119 of the Town Planning Act and the impugned regulations made by the Development Authority are unauthorised...

... IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH T, NEW DELHI BEFORE SH. G.S...: The present appeal has been filed by the assessee challenging the final assessment order dated 30.10.2018 passed under section 143 (3) r.w.s. 144 C of the Income Tax...finance processes within the group • Finance Planning & Analysis • Treasury - manage bank relations, cash management, etc...

...: • Global Head of Tax (Senior Vice President) • Corporate Vice President, Tax Planning • Corporate Vice Pre... Through: Mr. Manuj Sabharwal, Mr. Devvrat Tiwari & Mr. Drona Negi, Advocates. Versus INCOME-TAX OFFICER WARD INT TAX 1(1)(1), DELHI...Assessing Officer [AO] under Section 197 of the Income Tax Act, 1961 [Act], whereby the petitioner's application for 'NIL' withholding tax, was rejected. However, the AO had held that the...

...enacted to make provisions for planning and development and use of land; to make better provision for the preparation of the development plans and zoning plans with a view to ensuring that town planning...map”, “planning area”, “town development scheme” and “Town and Country Development Authority”, which are relevant for the purpose of this case, have been defined in Sections 2(f), 2(i), 2(o), 2(u) and 2...giving details of land use;(o) ‘planning area’ means any area declared to be a planning area under this Act; non-planning area shall be construed...

...standing evolved by Anglo-Saxon jurisprudence that only a person wronged can sue for judicial redress may not hold good in the present setting. Therefore, new strategy has to be evolved so that justice...Government on 8-8-1966 and the verified Andheri Town Planning Scheme framed under the Maharashtra Regional Town Planning Act, came into force, after the repeal of the Bombay Town Planning Act, with effect...the one for which it had been reserved and designated under the development plan as well as the town planning scheme and that it had no right to use it for commercial purpose. He also challenged the...