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ARTICLE · 23 OCTOBER 2025

Direct Tax Spotlight

Kochhar & Co.
Kochhar & Co.
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Kochhar & Co.

Kochhar & Co.

Kochhar & Co has one of the largest full service commercial law practices in Bangalore. The firm...

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It is a trite to say that India's judicial system is bursting at seams and matters linger before Tribunals and courts for decades

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INTRODUCTION

This edition brings you a significant update on Direct Tax, designed to keep you informed and ahead in an evolving regulatory landscape.

We trust you will find the insights useful, relevant, and timely.

NITI AAYOG WORKING PAPER ON "ENHANCING CERTAINTY, TRANSPARENCY AND UNIFORMITY IN PERMANENT ESTABLISHMENT AND PROFIT ATTRIBUTION FOR FOREIGN INVESTORS IN INDIA"

A. Niti Aayog has come up with a working paper on taxation of Permanent Establishment (PE) in India. The paper recognizes the importance of foreign direct investment (FDI) and foreign portfolio investment (FPI) in India's Economic Growth. It further acknowledges the role of stable, predictable, and transparent tax regime in instilling confidence of such foreign investors in India. It highlights that an unexpected PE trigger could lead to substantial and unforeseen tax liabilities on income arising out of Indian operations, which deter investments in India. To tackle this issue of

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