Articles by Hiral Raja

Advance Pricing Agreement - A Step Ahead

Hiral Raja 19 November 2012 at 11:44

Transfer Pricing provisions were brought under the purview of Income Tax Act in 2001. Over the years, there have been substantial amount of additions/adjustments at the time of transfer pricing assessments wherein the transfer price charged by th

Report of Expert Committee on General Anti Avoidance Rules

Hiral Raja 10 September 2012 at 14:08

Honble Prime Minister had constituted an Expert Committee on General Anti Avoidance Rules (GAAR) to undertake stakeholders consultations for finalization of guidelines to ensure greater clarity on GAAR issues. The Expert Committee af

MAT - Tax on Gross Assets- Whether fair and logical?

Hiral Raja 25 August 2009 at 11:33

Under the erstwhile Income Tax Act, 1961, MAT was levied u/s. 115 JB on book profits. The idea of levying MAT on book profits was to ensure that the entity pays tax at least on book profits even though the tax payable by it under the Income Tax Act c

Can Tribunal take back what assessing officer has given??

Hiral Raja 05 May 2009 at 15:44

Sub-section (1) of section 254 of the Income Tax Act, 1961 states as under: "254. (1) The Appellate Tribunal may, after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it thinks fit." The mo

Penalty u/s. 271(1)(C)

Hiral Raja 24 March 2009 at 23:03

If the Assessing officer or Commissioner (Appeals) in the course of any proceedings under the Act is satisfied that any person has concealed the particulars of his income or furnished inaccurate particulars of such income, then he can direct that suc

Rule 8D of the Income Tax Act - Prospective or Retrospective

Hiral Raja 05 February 2009 at 00:12

Section 14A was introduced in the Income Tax Act, 1961 by the Finance Act 2001 with retrospective effect from 1st April 1962. The intent of introducing this section was reiteration of the well settled legal principle that when an assessee incurs any