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Stream/Area:
-
Subject:
-
Paper ID:
IJSREM68148
Volume:
10 |
10 |
Oct 2026
Pages:
1-3
Publication Frequency:
Monthly (12 issues per year)
License:International Journal of Scientific Research in Engineering and Management follows the Creative Commons Attribution 4.0 (CC BY 4.0) License, allowing free use and distribution with proper attribution.
School of Law
SRM Institute of Science and Technology
Corporate tax sits at the point where a country’s need for revenue meets a company’s need for certainty. This paper examines how India taxes companies, starting with the basis of charge and the rules on residence, and then moving to the choice between concessional and regular regimes, the anti-avoidance toolkit, and the international pressures created by treaty abuse, base erosion and the global minimum tax. It follows the courts’ shifting view of tax planning, from McDowell to Azadi Bachao to the Vodafone controversy and its settlement in 2021. It also looks at the Income-tax Act, 2025, which replaced the 1961 Act from 1 April 2026. The study finds that rates have become simpler and more competitive, but disputes, retrospective-style amendments and compliance burdens still weaken predictability. The paper ends with practical suggestions to improve stability and trust.
KEYWORDS
Corporate tax in India is easier to understand than it was a decade ago. The headline rate is competitive, the option of a concessional regime is clear, and the new Act promises a tidier statute. Yet predictability, the quality that investors prize above almost any other, depends on more than rates. It depends on courts that decide cases quickly, on a legislature that avoids surprises and on administrators who apply rules consistently. If those conditions are met, the reform of 2025 will be remembered as the moment Indian corporate tax became both fair and dependable.
[1] Income-tax Act, 2025, India, assented Aug. 21, 2025, in force Apr. 1, 2026. [2] Income-tax Act, 1961, Act No. 43 of 1961, India. [3] Taxation Laws (Amendment) Act, 2019, India (introducing ss. 115BAA and 115BAB). [4] Taxation Laws (Amendment) Act, 2021, India. [5] Vodafone International Holdings B.V. v. Union of India, (2012) 6 SCC 613. [6] Union of India v. Azadi Bachao Andolan, (2003) 263 ITR 706 (SC). [7] McDowell & Co. Ltd. v. Commercial Tax Officer, (1985) 154 ITR 148 (SC). [8] Vodafone Group Plc v. Republic of India, PCA Case No. 2016-35, Award, Sept. 25, 2020; Cairn Energy Plc v. Republic of India, PCA Case No. 2016-7, Award, Dec. 21, 2020. [9] OECD, Tax Challenges Arising from the Digitalisation of the Economy: Global Anti-Base Erosion Model Rules (Pillar Two). Paris, France: OECD Publishing, 2021. [10] OECD, Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting. Paris, France: OECD, 2016.
Publication Date
10/20/2026
Peer Review Type
Double-Blind Peer Review
Review Rounds: 2
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Conflict of Interest
The authors declare no conflict of interest related to this research work.
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