Faceless penalty after assessment: why natural justice is becoming the decisive defence
Faceless penalty disputes in India are increasingly turning on procedural fairness. As digital assessments mature, natural justice is emerging as the most serious defence in penalty litigation.
GAAR in India after a decade: credible deterrent or underused headline provision?
A decade after GAAR entered the statute book, India’s anti-avoidance rule looks less like a daily weapon and more like a quiet constraint on how aggressive planning gets priced.
Treaty Shopping After Tiger Global: When Substance Starts to Trump Form
Treaty shopping disputes in India are moving from form to substance. After Tiger Global, the real issue is no longer paperwork alone, but who actually controls income, risk, and exit.
Tax certainty India: Board for Advance Rulings vs MAP vs APA – what corporates should choose now
India's tax-certainty architecture now rests on three very different routes. BAR offers domestic legal clarity, MAP delivers treaty relief, and APA has become the most institutionalised option for recurring transfer-pricing risk. The right choice depends on timelines, bilateral exposure and how much confidentiality a boardroom really needs.
Capital vs revenue in digital businesses: when old doctrines meet the cloud invoice
Capital vs revenue lines are fraying in India’s digital economy. SaaS subscriptions, cloud infrastructure, and data-driven intangibles create enduring benefits without durable assets, forcing doctrine to chase new facts
