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Two Certainities

Articles by Rav Singh

Portuguese Civil Code, Income Tax, and Companies Act: Understanding Beneficial Ownership 

The Bombay High Court, in a recent judgment, had to unravel the interplay of Portuguese Civil Code, IT Act, 1961, and the Companies Act, 1956 – among other issues – to ascertain the tax liability of assessees. While the case involved other issues, I will focus on the beneficial ownership aspect… Read More »Portuguese Civil Code, Income Tax, and Companies Act: Understanding Beneficial Ownership 

Supply of Vouchers and GST: Three Decisions and a Defensible Conclusion

This article focuses on the issue raised by M/s Kalyan Jewellers Limited (‘Kalyan Jewellers’) as regards the pre-paid instruments (‘PPI’)/vouchers issued by them to their customers. The claim of Kalyan Jewellers before the Advance Authority (‘AAR’), Appellate body for Advance Rulings (‘AAAR’), and thereafter before the Madras High Court was that the PPIs/vouchers issued by them… Read More »Supply of Vouchers and GST: Three Decisions and a Defensible Conclusion

Tax Residency Certificate and Stakes in Blackstone Case – I

In BlackStone case framed the following as the main issue for consideration: whether the Income Tax Department can go behind the tax residency certificate (‘TRC’) issued by another jurisdiction and issue a re-assessment notice under Section 147, IT Act, 1961 to determine the residence status, treaty eligibility and legal ownership. In this… Read More »Tax Residency Certificate and Stakes in Blackstone Case – I

An Ambiguous Circular: Is Electricity Indirectly under GST?

On 31.10.2023, CBIC issued a Circular clarifying the applicability of GST on certain services. The Circular, inter alia, clarified one issue which is the focus of this article. The issue, as framed by the Circular, was: Whether GST is applicable on reimbursement of electricity charges received by real estate companies, malls, airport operators… Read More »An Ambiguous Circular: Is Electricity Indirectly under GST?