Kunal Savani

Director in the Tax & Private Client Practice at the Mumbai office of Cyril Amarchand Mangaldas. Kunal specialises in various aspects of direct tax, such as corporate tax, M & A transactions, international tax and also specialises in succession and estate planning. He can be reached at kunal.savani@cyrilshroff.com

Firm/Organization: Cyril Amarchand Mangaldas

Blogs: Private Client

Latest Articles

India Tax Law

ITAT Puts On It’s Thin(king)-Cap – Treatment of Interest Paid on Compulsorily Convertible Debentures Under the Income Tax Laws

By Rishabh Shroff & Kunal Savani on August 12, 2019

The recent Income Tax Appellate Tribunal (ITAT) Order in CAE Flight Training (India) Pvt. Ltd. (TS-440-ITAT-2019 (Bang)) clarifies how Compulsorily Convertible Debentures (CCDs) are to be treated under Income Tax Laws. Before delving into the Order and what the ITAT said in making it, it is important to understand the legal context in which this question arose in the first place. To do this, we first need to understand the nature of a CCD. A…

India Tax Law

The Dilemma of Dual Residence – Can Vital Interests Fluctuate Overnight?

By Daksha Baxi, Kunal Savani & Sanjana Rao on May 13, 2019

The concept of dual residence crucially affects taxation of non-resident Indians and individuals who travel frequently between India and other countries. India follows a residence-based taxation system for residents, i.e., an Indian resident is taxed on his global income. A non-resident is taxed on income which is sourced or accrued or received in India. However, the confusion arises when an individual leaves the country and starts residing in another country under the laws of which…

Private Client

Prosecution Under Black Money Act for Inherited Foreign Bank Accounts

By Rishabh Shroff, Kunal Savani & Pratyush Khanna on March 27, 2019

The scourge of ‘black money’ has been a persistent issue for India, becoming a major political issue in the recent past. The problem of black money leads to challenges on multiple fronts, greatest of them being denial of revenue to the Government. The parallel economy created by black money deprives the government of its due share of individual income tax, which in turn leads to reduced funds available for much needed government spending and stimulus.…

India Tax Law

ITAT Holds Conversion of Company into LLP to be a Transfer

By Daksha Baxi, Kunal Savani & Bipluv Jhingan on December 11, 2018

The business form of Limited Liability Partnership (LLP) became available in India when the Limited Liability Partnership Act, 2008 (LLP Act) was enacted. Prior to this, businesses were organised as companies under the Companies Act. Small businesses find LLP to be a preferred form and since the LLP Act has a provision for conversion of a company into an LLP, many companies sought to convert to LLP. However, the question was whether such conversion would…

India Tax Law

NCLT Smell Tests GAAR! Rejects Ajanta Pharma’s Scheme of Merger on Grounds of Tax Avoidance

By S.R. Patnaik, Kunal Savani & Jyoti Anumolu on September 20, 2018

Recently, the National Company Law Tribunal (NCLT) rejected Ajanta Pharma Limited’s (Ajanta Pharma) scheme of amalgamation and arrangement (Scheme) between the company and its shareholder Gabs Investments Private Limited (Gabs Investments) on the grounds of General Anti Avoidance Rules (GAAR).…

Kunal Savani

ITAT Puts On It’s Thin(king)-Cap – Treatment of Interest Paid on Compulsorily Convertible Debentures Under the Income Tax Laws

The Dilemma of Dual Residence – Can Vital Interests Fluctuate Overnight?

Prosecution Under Black Money Act for Inherited Foreign Bank Accounts

ITAT Holds Conversion of Company into LLP to be a Transfer

NCLT Smell Tests GAAR! Rejects Ajanta Pharma’s Scheme of Merger on Grounds of Tax Avoidance

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