In a recent landmark ruling of Bangalore ITAT in case of Binny Bansal vs DCIT, the Hon'ble Bangalore ITAT has held that an Indian tax resident, despite overseas reclocation and foreign employment, may still be consireded as a Indian resident as per the Income Tax Act, 1961, if such individual maintains significant factutal and economic ties with India. In this article, let's analyse the concepts of center of vital interests and habitual abode, the dual tax treaty concepts th

The New Income-tax Rules, 2026 introduce a significantly modernised Safe Harbour framework under Indian Transfer Pricing, through introduction of range of Rules - from Rule 86 to Rule 102, replacing the earlier Rules. This article provides a detailed analysis of the new legislative structure, eligibility criteria, prescribed margins and admin procedure, thereby enabling practitioners, corporates and multinationals to have access to detailed analysis of the applicability and i