H - Rationalisation Measures- DIRECT TAXES

Country-by-country reporting expands transfer pricing disclosure, mandating master file and CbC submissions and penalties for non-compliance.

Amendments rationalise TDS and pass through taxation for Alternate Investment Funds and securitisation trusts by aligning withholding with resident or non resident rates, enabling lower or nil deduction certificates, and requiring trusts to disclose income composition. BEPS Action 13 implementation mandates master file and country by country reporting for large international groups with reporting obligations, verification powers and graded penalties. Procedural reforms shorten assessment timelines, mandate processing under section 143(1) before assessment, introduce section 270A for structured penalties on under reporting and misreporting, and permit bank guarantees in lieu of provisional attachment.