Buy back tax on listed shares
Under Sec 115QA; any amount of distributed income by a company on buy-back of shares from a shareholder is charged to tax at the rate of twenty per cent on the distributed income
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Thin Capitalisation
As per sec 94B, where an Indian company, or a PE of a foreign company in India, incurs any expenditure by way of interest or of similar nature exceeding one crore rupees which is deductible in computing income chargeable under the head "Profits and gains of business or profession" in respect of any debt issued by a non-resident, being an AE of such borrower, the interest shall not be deductible to the extent that it is in excess of thirty per cent of earnings before interest, taxes, depreciation and amortisation of the borrower in the previous year or interest paid or payable to associated enterprises for that previous year, whichever is less.
Black Money Dragon
There shall be charged on every assessee for every assessment year commencing on or after the 1st day of April, 2016, a tax in respect of his total undisclosed foreign income and asset of the previous year at the rate of thirty per cent of such undisclosed income and asset.
Deemed International Transaction
A transaction with unrelated party shall be deemed to be an international transaction with AE, if there is a prior agreement between such unrelated party and AE or the essential terms are determined by such person and AE relevant to the above referred transaction
Search and Seizure Assessments under new regime
Under sec 148, where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A, on or after the 1st day of April, 2021, in the case of the assessee; the AO shall be deemed to have information which suggests that the income chargeable to tax has escaped assessment in the case of the assessee for the three assessment years immediately preceding the assessment year relevant to the previous year in which the search is initiated or books of account, other documents or any assets are requisitioned or survey is conducted in the case of the assessee or money, bullion, jewellery or other valuable article or thing or books of account or documents are seized or requisitioned in case of any other person.
Catching the Benami Transactions
Whoever enters into any benami transaction shall be punishable with imprisonment for a term which may extend to three years or with fine or with both
Equalisation Levy on ecommerce supply of services
W.e.f 01.04.2020 there shall be charged an equalisation levy at the rate of two per cent. of the amount of consideration received or receivable by an e-commerce operator from e-commerce supply or services made or provided or facilitated by it to a person resident in India or to a non-resident in the specified circumstances to a person who buys such goods or services or both using internet protocol address located in India
General Anti Avoidance Agreement
An arrangement entered into by an assessee may be declared to be an impermissible avoidance arrangement and the consequence in relation to tax arising therefrom may be determined subject to the provisions of General Anti Avoidance Rules
