Special measures for notified jurisdictional areas deem parties associated and restrict deductions without prescribed authorization. Special measures treat transactions with persons located in a notified jurisdictional area as involving associated enterprises and as international transactions for purposes of transfer-pricing and anti-avoidance provisions; deductions for payments to financial institutions in such areas require a prescribed authorization allowing authorities to obtain information, other expenditures require prescribed records, unexplained receipts from such persons may be deemed the assessee's income, and withholding obligations are applied at the highest applicable statutory rate.
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.
Special measures for notified jurisdictional areas deem parties associated and restrict deductions without prescribed authorization.
Special measures treat transactions with persons located in a notified jurisdictional area as involving associated enterprises and as international transactions for purposes of transfer-pricing and anti-avoidance provisions; deductions for payments to financial institutions in such areas require a prescribed authorization allowing authorities to obtain information, other expenditures require prescribed records, unexplained receipts from such persons may be deemed the assessee's income, and withholding obligations are applied at the highest applicable statutory rate.
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