Two Certainties
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IT Act, 2025
A timeline of the past decade. As I elaborate in a related post - the IT Act, 2025 has a longer (and opaque) history than widely believed.
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Income Tax Act, 2025: A ‘Reform’ Comes to Life
The Income Tax Act, 2025 (IT Act, 2025) – after almost a decade of attempts to redraft income tax law - comes into force on 1 April 2026 and replaces the Income Tax Act, 1961 (IT…
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Money Displaces Skill-Chance Distinction: Examining Taxation and Regulatory Approaches to Online Gaming
The Central Goods and Services Tax Act, 2017 (‘CGST Act, 2017’) and The Promotion and Regulation of Online Gaming Act, 2025 (‘OGA, 2025’) use money as the criteria to differentiate between various kinds of online gaming. In both legislations…
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Buyback Tax: An Anti-Abuse Measure Wrapped in a Tax
Finance Bill, 2026 proposes to amend buyback tax. Yet again. The proposed amendment simultaneously simplifies and complicates buyback tax. Latter because of the proposal to create a separate tax slab for promoters of companies who participate in…
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Supreme Courts Uses Tax Sovereignty to Hunt Tiger Global
The Supreme Court recently handed a significant legal victory to the Income Tax Department (‘Revenue’) in The Authority for Advance Rulings (Income-Tax) & Ors v Tiger Global International III Holdings (‘Tiger Global case’). And in the process created…
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Health and National Security Cess: Some Context
The Lok Sabha on 5th December 2025, passed the Health Security se National Security Cess Bill, 2025. The Health se National Security Cess (‘Health and National Security Cess’) is an unusual marriage of public health and national…
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In Applause of a Repeal: Place of Supply for Intermediary Services
The Goods and Services Tax Council (‘GST Council’) in its 56th meeting took multiple decisions and made a series of recommendations. The headline, of course, was dominated by the change in tax rates of various goods. An equal,…
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Time Restraint on Power of Provisional Attachment under GST
Introduction The Supreme Court in Kesari Nandan Mobile v Office of Assistant Commissioner of State Tax (‘Kesari Nandan Mobile’) held that an order of provisional attachment under Section 83 of the Central Goods and Services Act, 2017 (‘CGST…
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Parallel Proceedings under GST: Supreme Court Misses an Opportunity
Introduction Recently, the Supreme Court in M/S Armour Security (India) Ltd v Commissioner, CGST, Delhi East Commissionerate & Anr (Armour Security case) clarified scope of the terms ‘proceedings’ and ‘same subject matter’ used in Section 6(2)(b) of the…
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Taxation of ESOP-Related Compensation: Reviewing the Flipkart Cases
Introduction In April 2023, the Board of Flipkart Private Limited (‘FPS’), Singapore decided to pay a one-time voluntary compensation - 43.67 US dollars per stock option - to all the option grantees of its Employee Stock…
