Tax 360

We are pleased to share the first edition of our quarterly direct tax publication, Tax 360.

On the international tax front, this quarter saw important developments, including the Delhi High Court’s ruling that reimbursements under deputation arrangements are taxable as fees for included services, and the Delhi Tribunal’s decision that pure reimbursements are not taxable. In the M&A context, the Mumbai Tribunal’s ruling denying the carry-forward and set-off of accumulated losses of approximately INR 2.4 billion will be closely reviewed when structuring demerger and hive-off transactions.

The Income Tax Act, 2025 replaced the Income Tax Act, 1961 from 01 April 2026. Several interpretational and implementation related issues are expected to arise. To support effective implementation, the CBDT has issued detailed FAQs addressing various transitional matters.