Hong Kong tabled the Inland Revenue (Amendment) (Miscellaneous Provisions) Bill 2021 in parliament on March 24.

On April 1, 2021, the Inland Revenue Authority of Singapore issued a summary of an advance ruling concerning franchise income earned by a Singaporean company from licensing intellectual property rights.

The New Zealand Inland Revenue Department has released a new "special report" to provide guidance on changes to real property tax rules and other tax rules that were included in the Taxation (Annual Rates for 2020–21, Feasibility Expenditure, and Remedial Matters) Act 2021.

Chinese authorities have announced enhanced temporary tax breaks for small businesses.

Experts speaking at the UN's Economic and Social Council's annual Special Meeting on International Cooperation in Tax Matters concluded that the international community must do more to tackle tax base erosion and profit shifting and offshore tax evasion.

On May 3, 2021, the Hong Kong Inland Revenue Department issued over 2.62 million tax returns for individuals for the year of assessment 2020-21.

Hong Kong's Legislative Council has passed a bill to implement a series of amendments to the Inland Revenue Ordinance.

Mauritius announced numerous tax relief measures for investors and for wealthy foreign individuals in its newly released Budget.

New Zealand has announced further extensions to due dates for applications for the country's research and development tax incentive for the 2019-20 and 2020-21 income years.

The OECD has said 131 countries and jurisdictions have put their name to an international agreement on an overhaul to tax rules for the digitalized economy and for large multinational businesses.

Thailand's Revenue Department has released new English-language guidance on the value-added tax rules for business-to-consumer supplies of electronic services rendered by non-resident businesses.

Hong Kong's Secretary for Financial Services and the Treasury, Christopher Hui Ching-yu, has set out how the territory intends to respond to the OECD's proposed new international tax framework.

Senate Finance Committee Chair Ron Wyden (D-OR) has introduced legislation to overhaul the 20 percent deduction for pass-through income introduced into US tax law in 2017.

On August 1, 2021, Mexico's federal tax authority released a second report on the effective corporate tax paid by large businesses in various economic sectors.

The Indonesian Government has legislated to shoulder the value-added tax liability of retail businesses on rent and service charges due between August and October 2021.

The Hong Kong Government has said it is looking at potential measures to support the shipping industry following the decision by the US Government to terminate the two territories' agreement that exempted shipping industry income from tax.

The Dutch Government has announced changes aimed at improving the tax system in its 2022 Tax Plan, released on September 21.

The Hong Kong Government has issued a statement committing to amend its tax law with regards the tax exemption for foreign source passive income from 2023, to ensure the territory does not end up placed on the EU's tax blacklist of non-cooperative territories.

Following a consultation exercise, the Inland Revenue Authority of Singapore has said the territory intends to go ahead with various important goods and services tax regime changes without accepting amendments proposed by stakeholders.

Indonesia's lower house of parliament has signed off on a bill that provides for a two-stage hike to the headline value-added tax rate, the cancellation of a planned corporate tax cut, and the introduction of a new top rate of personal income tax.

With the UK corporate tax rate set to rise 25 percent from April 2023, the UK Government has announced various tax proposals that are intended to support businesses and the UK economy, in the newly released 2022 Budget.

Singapore's Minister of Finance has said Singapore will set out plans to hike its carbon tax in the 2022 Budget.

HM Revenue and Customs is reforming late-filing and payment penalties to make them fairer and more consistent across taxes. The first stage of these reforms was set to come into effect early this year. However, on January 13, 2022, HMRC postponed the effective dates by nine months to one year.

The Turkish Government has recently enacted Law No. 7,351, which provides corporate tax reliefs for exporters and manufacturing businesses.

The US Internal Revenue Service (IRS) has suspended the use of more than a dozen additional letters, including the mailing of automated collection notices, normally issued when a taxpayer owes additional tax and the IRS has no record of a taxpayer filing a tax return.

Singapore has announced personal income tax hikes and higher wealth taxes on the territory's wealthiest individuals, as well as plans to ramp up the territory's carbon tax, in its newly released Budget.

The Guernsey Government on April 26, 2022, announced that a parliamentary debate on tax reform, scheduled for July, will now be delayed until the end of the year, to allow time for consideration of corporate tax options. Earlier, Guernsey's Policy and Resources Committee proposed that the territory could implement a goods and services tax to buoy the territory's finances.

The British Virgin Islands' Inland Revenue Department is to introduce a new platform from early next year to automate the administration of all taxes and licenses.

Eight cities across the United States have introduced taxes on sugar-sweetened beverages, which are linked to health problems such as obesity and Type 2 diabetes (!--ref1--).

The GST Council, led by Finance Minister Nirmala Sitharaman, has formed a Group of Ministers to evaluate reducing GST rates on life and health insurance,

The needs of all Australians - affordable housing, a secure job, a decent education for their children, a good health system and a comfortable retirement - will not be met if we don't achieve major tax reform.

At PwC we have put significant effort into generating a national conversation about Australia's tax system and the need to improve it.

Major tax reform is the most sensible lever to pull to combat a projected $48 billion in lost revenue in our new low growth economy.

If the company tax rate was reduced from 30 to 25 per cent over the next five years gross domestic product (GDP) would grow $291 billion and income tax revenues would generate $4 billion up to the year 2025, PwC modelling released today shows.

These are appeals preferred by the assessee against orders of the Learned Commissioner of Income Tax (Appeals)/NFAC, (hereinafter in short "the Ld.CIT(A)"), Delhi, dated 19.02.2024/20.02.2024 for the Assessment Year (hereinafter in short "AY") 2017-18.

2. First, will take up ITA No 701/Chny/2024 against Ld CIT(A) order dated 19.02.2024; and note that the main grievance of the assessee is against the action of the Ld.CIT(A) confirming the following actions of the AO (i) making an addition of Rs.19,28,069/- as unexplained money on ITA Nos.701, 743 to 745/Chny/2024 (AY 2017-18) M/s. Covai Marketing :: 2 ::

This is an appeal filed by the Assessee directed against the order of ld.Commissioner of Income Tax(Appeal)[NFAC], under section 250 of the Income tax Act, 1961 dated 28.06.2024 for A.Y.2019-20. The assessee has raised the following grounds of appeal :

"1. The Ld.CIT(A) has wrongly confirmed the disallowance of deduction of Rs.15,60,115/- claimed by the appellant u/s.80P(2)(a)(i) of the Income Tax Act, 1961.

2. Alternatively, the interest income earned by the appellant from the investments in a co-operative bank is also eligible for deduction under section 80P(2)(d) of the Income Tax Act, 1961.

3. The Appellant crave leave to add, delete, amend, alter, vary and/or withdraw all or any one of the above grounds of appeal."

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI "B" BENCH: NEW DELHI BEFORE SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER & SHRI YOGESH KUMAR US, JUDICIAL MEMBER [Assessment Year : 2014-15] ITO, vs Discoveri Media Group, Gurgaon. 97B, Udyog Vihar, Phase-V, Gurgaon-122002.

PAN-AAIFD8766G APPELLANT RESPONDENT [Assessment Year : 2014-15] Discoveri Media Group vs ITO, C/o-S.L.Poddar & Co., Ward-1(4), Gokul Apartment, E-3A, Kantichandra Gurugram. Road, Bani Park, Jaipur, Rajasthan-302016. PAN-AAIFD8766G APPELLANT RESPONDENT [Assessment Year : 2015-16] ITO, Vs Discoveri Media Group, Gurgaon. 97B, Udyog Vihar, Phase-V, Gurgaon-122002. PAN-AAIFD8766G APPELLANT RESPONDENT [Assessment Year : 2015-16] Discoveri Media Group, vs ITO, 97B, Udyog Vihar, Phase-V, Ward-1(4), Gurgaon-122002. Gurugram. PAN-AAIFD8766G APPELLANT RESPONDENT Appellant by Shri S.L.Poddar, Adv. Respondent by Shri B. K.Singh, Sr.DR Date of Hearing 01.10.2024 Date of Pronouncement 12.11.2024 Page | 1

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI "B" BENCH: NEW DELHI BEFORE SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER & SHRI YOGESH KUMAR US, JUDICIAL MEMBER [Assessment Year : 2014-15] ITO, vs Discoveri Media Group, Gurgaon. 97B, Udyog Vihar, Phase-V, Gurgaon-122002.

PAN-AAIFD8766G APPELLANT RESPONDENT [Assessment Year : 2014-15] Discoveri Media Group vs ITO, C/o-S.L.Poddar & Co., Ward-1(4), Gokul Apartment, E-3A, Kantichandra Gurugram. Road, Bani Park, Jaipur, Rajasthan-302016. PAN-AAIFD8766G APPELLANT RESPONDENT [Assessment Year : 2015-16] ITO, Vs Discoveri Media Group, Gurgaon. 97B, Udyog Vihar, Phase-V, Gurgaon-122002. PAN-AAIFD8766G APPELLANT RESPONDENT [Assessment Year : 2015-16] Discoveri Media Group, vs ITO, 97B, Udyog Vihar, Phase-V, Ward-1(4), Gurgaon-122002. Gurugram. PAN-AAIFD8766G APPELLANT RESPONDENT Appellant by Shri S.L.Poddar, Adv. Respondent by Shri B. K.Singh, Sr.DR Date of Hearing 01.10.2024 Date of Pronouncement 12.11.2024 Page | 1

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI "B" BENCH: NEW DELHI BEFORE SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER & SHRI YOGESH KUMAR US, JUDICIAL MEMBER [Assessment Year : 2014-15] ITO, vs Discoveri Media Group, Gurgaon. 97B, Udyog Vihar, Phase-V, Gurgaon-122002.

PAN-AAIFD8766G APPELLANT RESPONDENT [Assessment Year : 2014-15] Discoveri Media Group vs ITO, C/o-S.L.Poddar & Co., Ward-1(4), Gokul Apartment, E-3A, Kantichandra Gurugram. Road, Bani Park, Jaipur, Rajasthan-302016. PAN-AAIFD8766G APPELLANT RESPONDENT [Assessment Year : 2015-16] ITO, Vs Discoveri Media Group, Gurgaon. 97B, Udyog Vihar, Phase-V, Gurgaon-122002. PAN-AAIFD8766G APPELLANT RESPONDENT [Assessment Year : 2015-16] Discoveri Media Group, vs ITO, 97B, Udyog Vihar, Phase-V, Ward-1(4), Gurgaon-122002. Gurugram. PAN-AAIFD8766G APPELLANT RESPONDENT Appellant by Shri S.L.Poddar, Adv. Respondent by Shri B. K.Singh, Sr.DR Date of Hearing 01.10.2024 Date of Pronouncement 12.11.2024 Page | 1

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI "B" BENCH: NEW DELHI BEFORE SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER & SHRI YOGESH KUMAR US, JUDICIAL MEMBER [Assessment Year : 2014-15] ITO, vs Discoveri Media Group, Gurgaon. 97B, Udyog Vihar, Phase-V, Gurgaon-122002.

PAN-AAIFD8766G APPELLANT RESPONDENT [Assessment Year : 2014-15] Discoveri Media Group vs ITO, C/o-S.L.Poddar & Co., Ward-1(4), Gokul Apartment, E-3A, Kantichandra Gurugram. Road, Bani Park, Jaipur, Rajasthan-302016. PAN-AAIFD8766G APPELLANT RESPONDENT [Assessment Year : 2015-16] ITO, Vs Discoveri Media Group, Gurgaon. 97B, Udyog Vihar, Phase-V, Gurgaon-122002. PAN-AAIFD8766G APPELLANT RESPONDENT [Assessment Year : 2015-16] Discoveri Media Group, vs ITO, 97B, Udyog Vihar, Phase-V, Ward-1(4), Gurgaon-122002. Gurugram. PAN-AAIFD8766G APPELLANT RESPONDENT Appellant by Shri S.L.Poddar, Adv. Respondent by Shri B. K.Singh, Sr.DR Date of Hearing 01.10.2024 Date of Pronouncement 12.11.2024 Page | 1

YASHWANT VARMA, J.

1. The Commissioner of Income Tax (TDS) impugns the judgment rendered by the Income Tax Appellate Tribunal1 on 10 April 2017 Tribunal and which has principally held that the capital grant subsidy given by the respondent-assessee to its Concessionaires would not be subject to a withholding tax as contemplated under Section 194C of the Income Tax Act, 19612.

2. We had upon hearing learned counsels for respective sides on 19 March 2024 admitted the appeal on the solitary issue of deduction of tax at source. The said order is reproduced hereinbelow:-

YASHWANT VARMA, J.

1. The Commissioner of Income Tax (TDS) impugns the judgment rendered by the Income Tax Appellate Tribunal1 on 10 April 2017 Tribunal and which has principally held that the capital grant subsidy given by the respondent-assessee to its Concessionaires would not be subject to a withholding tax as contemplated under Section 194C of the Income Tax Act, 19612.

2. We had upon hearing learned counsels for respective sides on 19 March 2024 admitted the appeal on the solitary issue of deduction of tax at source. The said order is reproduced hereinbelow:-

The Court:- This appeal by the revenue filed under Section 260A of the Income Tax Act, 1961 (the Act) is directed against the order dated November 08, 2023 passed by the Income Tax Appellate Tribunal 'A' Bench, Kolkata (the Tribunal) in ITA No.666/Kol/2023 for the assessment year 2012-13.

The revenue has raised the following substantial questions of law for consideration:-

(a) Whether on the facts and circumstances of the case and in law, the Learned Income Tax Appellate Tribunal has committed substantial error by not considering the addition made by the Assessing Officer on account of share capital / share premium of Rs.3,00,00,000/- made u/s 68 of the IT Act, 1961, without considering the fact that there is accommodation entry in the instant case?

learned advocate on record of the appellant is directed to serve notice of appeal on the respondent in the meantime.

(T. S. SIVAGNANAM, C.J.) (HIRANMAY BHATTACHARYYA, J.) S. Kumar

The Court : This is an appeal filed by the revenue under Section 260A of the Income Tax Act, 1961 (the Act) challenging an order dated January 11, 2024 passed by the Income Tax Appellate Tribunal, "B" Bench, Kolkata (Tribunal) in I.T.A No.763/Kol/2022, for the assessment order 2013-14.

We have heard Mr. Aryak Dutt, learned standing counsel appearing for the appellant and Mr. Soumitra Chowdhury, learned counsel for the respondent/assessee.

The appeal was filed beyond time and an application for condonation of delay was filed which was heard and the delay was condoned. Learned counsel appearing for the assessee would submit that the assessee has been advised to avail the provisions of the direct tax Vivad Se Viswas Scheme (VSVS) dated 15 th October, 2023. However, one issue may crop up if the assessee files an application under VSVS by citing that the duty fixed for eligible cases as has been mentioned in paragraph 3(Sl.1)(ii). Identical issue arose for consideration before this Court in the case of Principal Commissioner of Income Tax-1, Kolkata vs. Asish Kumar Ghosh, WPA 18282 of 2021 and by judgment dated 1st April, 2022 this Court had considered the very same issue and found that the assessee would be eligible to file a declaration under the provisions of the VSVS and a direction was also issued to process such application. The judgment rendered in Asish Kumar Ghosh will fully support the case of the assessee and therefore the assessee is entitled to file an application under the VSVS. Accordingly, the assessee is directed to file an application and the department shall process the application in accordance with law.

The Court:- This appeal by the assessee filed under Section 260A of the Income Tax Act, 1961 (the Act) is directed against the order dated January 16, 2024 passed by the Income Tax Appellate Tribunal 'C' Bench, Kolkata (the Tribunal) in ITA No.1964/Kol/2019 and C.O. No.39/Kol/2019 for the assessment year 2015-16. This appeal is admitted on the following substantial questions of law:-

(i) Whether the Tribunal was justified in law in upholding the invocation of sub-section (2) of section 14A of the Income Tax Act, 1961 and rule 8D(2)(iii) of the Income Tax Rules, 1962, in the absence of any satisfaction recorded by the Assessing Officer that having regard to the accounts of appellant, the appellant's claim that expenditure of Rs.9,77,888/ was incurred in relation to the exempt income was not correct?

The Court :- We have heard the learned Advocates for the parties. The revenue has filed this appeal under Section 260A of the Income Tax Act, 1961 (the Act) is directed against the order dated 9th May, 2023 passed by the Income Tax Appellate Tribunal "B" Bench, Kolkata (the Tribunal) in ITA/491/Kol/2021 for the assessment year 2011-12. The revenue has raised the following substantial questions of law for consideration:-

a. Whether the learned Tribunal has committed substantial error in law in granting relief to the assessee without considering the fact that neither the assessee nor the amalgamating company informed the AO about the scheme of amalgamation approved by the Hon'ble High Court and therefore defect in not issuing notice in the name of amalgamated company remained a curable defect under section 292B of the Income Tax Act, 1961 ?

The Court : This appeal filed by the revenue under Section 260A of the Income Tax Act, 1961 (the Act) is directed against an order dated October 26, 2023, passed by the Income Tax Appellate Tribunal, "C" Bench, Kolkata (Tribunal) in I.T.A No.1842/Kol/2017, for the assessment order 2009-10.

The revenue has raised the following substantial questions of law for consideration:-

i) Whether on the facts and in law, the Hon'ble ITAT is justified in setting aside the order of the Ld. CIT(A) and deleting the additional made by the A.O. towards unexplained share capital and share premium of Rs.15,51,00,000/- u/s. 68 of the Act by holding that the assessee had discharged its onus to prove the identity and creditworthiness of the share subscribing companies and the genuineness of the transactions overlooking the fact that not even a single Director of the share subscribing companies appeared before the Assessing Officer nor provided a valid reason for their non-appearance?

RESERVED ON : 11th NOVEMBER 2024 PRONOUNCED ON: 12th NOVEMBER 2024 _______________________ Judgment (Per Advait M. Sethna, J.)

1. Rule, made returnable forthwith. Respondents waive service. By consent of the parties, the petition is heard finally.

NOVEMBER 12, 2024 18-WP(L)-17982-2024(J).DOCX

2. This petition is filed under Article 226 of the Constitution of India. Briefly, the petition challenges an order dated 30 th March 2024 passed by respondent No.1 ("impugned order" for short). By the said order, the application filed by the petitioner dated 9 th November 2022 seeking waiver of interest charged under Section 234C of the Income Tax Act, 1961 ("Income Tax Act" for short) for the Assessment Year 2021-22 ("A. Y. Year 2021-22" for short) stood rejected. The reliefs/prayers in the petition are set out at pages 52 to 54 in para 12 thereof. The substantive relief/prayer is to quash and set aside the impugned order passed by respondent No.1 and to grant waiver of interest for an amount of Rs.3,88,59,353/- charged under Section 234C of the Income Tax Act. Such is the limited issue for consideration before us.

Beijing and Washington have been at loggerheads on issues from tech to human rights and territorial claims, but a recent global tax deal shows how the rivals can also cooperate. WSJ looks at what’s next for U.S.-China relations as the G-20 meets in Rome. Photo Composite: Sharon Shi