General anti-avoidance rule strengthened to permit declaration of impermissible tax-avoidance arrangements and determine tax consequences. The Bill revises tax rates, withholding rules and surcharge/cess application; clarifies key definitions and the situs of property and income; tightens and extends various deductions and incentive timeframes; expands transfer-pricing law to include specified domestic transactions with attendant documentation, valuation and penalty consequences; introduces a comprehensive general anti-avoidance rule with a Commissioner referral and Approving Panel process binding on Assessing Officers; extends reopening and limitation rules for offshore assets and reporting failures; establishes new withholding, reporting and penalty regimes, graded search-related penalty provisions, Special Courts for tax offences, and multiple procedural and appellate adjustments, many with specified retrospective or prospective effective dates.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
General anti-avoidance rule strengthened to permit declaration of impermissible tax-avoidance arrangements and determine tax consequences.
The Bill revises tax rates, withholding rules and surcharge/cess application; clarifies key definitions and the situs of property and income; tightens and extends various deductions and incentive timeframes; expands transfer-pricing law to include specified domestic transactions with attendant documentation, valuation and penalty consequences; introduces a comprehensive general anti-avoidance rule with a Commissioner referral and Approving Panel process binding on Assessing Officers; extends reopening and limitation rules for offshore assets and reporting failures; establishes new withholding, reporting and penalty regimes, graded search-related penalty provisions, Special Courts for tax offences, and multiple procedural and appellate adjustments, many with specified retrospective or prospective effective dates.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.