News & Media 10th Oct 2025

NITI Aayog’s proposal for presumptive tax raises double-taxation concerns

Authors

Rahul CharkhaPartner | Pune

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Our Partner, Rahul Charkha was quoted in The New Indian Express’s latest article, “NITI Aayog’s proposal for presumptive tax raises double-taxation concerns”, by Pushpita Dey.

Mr. Charkha noted that under the current framework, profit attribution to a permanent establishment follows the ‘separate and independent enterprise’ principle. He cautioned that if the proposed regime effectively replaces this system, it could hinder taxpayers from claiming treaty benefits and heighten the risk of double taxation.

Read the article here

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