General Anti-Avoidance Rule deferred, revenue bears onus and taxpayers may seek Advance Rulings on arrangements. The Finance Act, 2012 introduces targeted amendments: a tax exemption for Prasar Bharati effective 1 April 2013; substantive modification and one year deferral of GAAR with Revenue bearing onus, addition of an independent law member to the GAAR Approving Panel and AAR access for taxpayers; retention of VCC/VCF exemptions from TDS/DDT; extension of a 5% withholding rate for external borrowings and approved infrastructure bonds to all businesses; a 10% concessional tax rate on long term capital gains for non resident transfers of unlisted securities; treatment of excess share premium as income with potential notified exemptions; new retail equity deduction under section 80CCG; various TCS/TDS threshold adjustments; withdrawal of proposed TDS on immovable property transfers; and clarifications on DRP and TDS procedural language.
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 deferred, revenue bears onus and taxpayers may seek Advance Rulings on arrangements.
The Finance Act, 2012 introduces targeted amendments: a tax exemption for Prasar Bharati effective 1 April 2013; substantive modification and one year deferral of GAAR with Revenue bearing onus, addition of an independent law member to the GAAR Approving Panel and AAR access for taxpayers; retention of VCC/VCF exemptions from TDS/DDT; extension of a 5% withholding rate for external borrowings and approved infrastructure bonds to all businesses; a 10% concessional tax rate on long term capital gains for non resident transfers of unlisted securities; treatment of excess share premium as income with potential notified exemptions; new retail equity deduction under section 80CCG; various TCS/TDS threshold adjustments; withdrawal of proposed TDS on immovable property transfers; and clarifications on DRP and TDS procedural language.
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