Tag: CBDT

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.

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 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

A tax opinion in 2026 survives less on elegant citation than on facts, disclosure and process. As scrutiny gets more data-rich, defensibility now begins long before the notice arrives.

Section 148 still dominates tax conversations, but reopening is no longer the Department’s only preferred battlefield. In 2025–26, revision is increasingly the cleaner weapon against weak assessments, while search has been pushed into a separate, evidence-heavy block-assessment track.