The amendments carried out in the Income Tax Rules state that Rule 10U( 1)( d) has been amended to provide that GAAR
will not apply to income earned/ received by any person from transfer of investments made before April 1, 2017.
When amended in 1982, div 13 was not, however, intended as an 'antiavoidance' provision, despite being referred to as such in the second reading speech to the Bill for the Act which introduced the new GAAR
, namely pt IVA.
The draft measures provide guidance on, among other things, when a tax avoidance case is present, policies and procedures on selection of GAAR
cases by in-charge authorities, documents that may be requested from the taxpayer in connection with a GAAR
examination, and the types of tax adjustments that may be made to deny tax benefits for transactions without reasonable business purpose.
1), and encompassed the southern flanks of the central Brooks Range, including the southeastern portion of GAAR
, all of KNWR, and other state, federal, private, and native lands.
INTERPRETATION OF STATUTES IN THE SUPREME COURT OF CANADA: THE GAAR
will bring in a blanket legislation to differentiate between what is responsible, legitimate tax planning and what is classed as abusive tax avoidance.
Rob Gunn, tax partner at business advisory and accounting firm RSM Tenon's Birmingham office, agreed the GAAR
would be central to the speech.
The Parthasarathi Shome panel appointed to look into the GAAR
has made some very sensible suggestions: indirect transfer of Indian assets should be taxed only prospectively except in rare cases; interest and penalty should be waived in such cases and, most important, the tax has to be levied on the party, which made money and not the one who paid.
We addressed investor concerns by appointing the Partho Shome committee to look into the implementation of GAAR
and the tax treatment of certain investments.
, as the name suggests, are aimed at discouraging Indian companies and investors from routing their investments through tax havens just to avoid taxes
6) Of course, anyone who really believed that the GAAR
would have such an effect has since been proven wrong.
The Prime Minister's Office (PMO) has already set up an expert committee for making suggestions on draft guidelines and framing a roadmap for the implementation of GAAR