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Novation in International Tax Treaties

Rashi Chopra Senior Associate, UBR Legal Advocates Vishwaranjan Associate, UBR Legal Advocates AbstractThe jurisprudential interpretation of the principle of novation in tax treaties and its procedural implications under domestic tax laws was critically analysed in the Delhi High Court’s decision in Sneh Lata Sawhney v. CIT [TS-592-HC-2025(DEL)] [1]. This judgment underscores the relevance of treaty…

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Crypto or Cryptic? Conundrum of Taxation of Virtual Currencies

IntroductionVirtual currencies, the most popular of them being ‘bitcoin’, have taken the world by a storm in this last decade. Currently, there are over 1600 virtual currencies being circulated. This number is growing. Unlike money, which is legal tender, virtual currencies are decentralized, unregulated and uninhibited. Cryptoassets, and virtual currencies in particular, are in rapid…

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Cannon India Overruled?

Introduction  Even though God rules in the affairs of men, the earth is not God’s jurisdiction. It is man’s jurisdiction. This quote is apt to set the tone for this piece relating to the “jurisdiction” of the “proper officer” of DRI. It is a much-debated question. However, in my humble opinion, it is a self-inflicted…

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