Transfer pricing reference: a new TPO referral is needed only if fresh facts emerge after a search.
A fresh reference to the TPO under Section 92CA(1) is not automatic in search-related reassessments; it is required where the AO deems it necessary or expedient. If a prior TPO reference existed but the TPO report was not received or the assessment was not completed before initiation of action under Section 132/132A, those proceedings abate and a new reference will be required during Section 153A/153C proceedings. If the assessment was completed taking the TPO report into account before the search, it does not abate and a fresh reference is needed only if further facts relevant to transfer pricing are discovered.

Preventive vigilance: reinforced obligations on tax officials to ensure a corruption-free administration and swift disciplinary action.
Preventive Vigilance is reaffirmed as the primary administrative mechanism to ensure a tax administration free from corruption, bias, or favouritism. Vigilance wings must expeditiously conclude disciplinary proceedings, protecting the innocent while imposing strict action for gross misconduct. Senior officers must inspect subordinates, counsel staff, secure vulnerable areas, engage stakeholders for feedback, and implement systematic rotation between sensitive and non-sensitive assignments to prevent vested interests and protect objective official functioning.

Hearing fixation policy: suspend automatic sixty day scheduling and cap daily bench listings to reduce overloading and adjourn excess.
Manpower shortages and increased pendency render the practice of fixing new appeals on the 60th day impracticable. New appeals should be kept pending and fixed in regular course. Regular case listings before each Bench should not exceed twenty (excluding covered/group matters); where regular cases exceed that limit the excess shall be adjourned to the next available date after obtaining the Vice President's order. The Department's grievances about last minute additions, inadequate preparation time for Departmental Representatives, poor recording of arguments, and adverse comments for non representation are to be circulated to Bench Members for consideration.

Stakeholder committees for IT modernization invited to finalise software requirements and contribute implementation suggestions.
Selection of a service provider for rewriting the Income Tax Department's software suite is complete pending expenditure committee approval and contract execution. The project encompasses re writing applications in new architecture, developing a data centre, technology training and test environments, an HRMS module, legacy maintenance, non core process software, and interfaces with external systems. New functional modules will cover PAN, ITR processing, TDS interface, post processing, investigation, international taxation, recovery, appeals, exemptions, audit, document management and reporting. Specialist committees will be formed to prepare detailed software requirement specifications and stakeholders are invited to volunteer or submit suggestions via the programme email.

International taxation cooperation: member countries agree coordinated measures against treaty abuse, information gaps and profit shifting.
Heads of revenue agreed a cooperative framework to address international taxation and transfer pricing by adopting seven areas of joint action-development of international standards, strengthened enforcement and international cooperation against non compliance, sharing best practices and capacity building, countering treaty abuse and complex profit shifting, establishing a BRICS mechanism to counter abusive avoidance, promoting effective exchange of information, and other common tax policy concerns-and to establish central points of contact and a Governance Framework to coordinate responses and share resources.

Exchange of Information: route tax information requests through designated competent authorities to ensure timely, confidential responses.
Outbound and inbound tax information requests must be routed through the designated Competent Authorities (JS(FT&TR I) for North America/Europe/Japan; JS(FT&TR II) for the rest of the world) using the prescribed Proforma. Requests must state the tax purpose, time period, grounds that the information is held in the requested jurisdiction, and foreseeable relevance; separate Proformas are required per taxpayer and per country. Field units must meet prescribed timelines, provide interim/final Annexure G/I reports and feedback within two months, and maintain strict confidentiality and secure handling of exchanged data.

Deemed export for on site software development preserves tax incentives when linked by contract to the eligible Indian unit.
Profits from software developed abroad at a client's site are deemed export and eligible for benefits under sections 10A, 10AA and 10B where there is a direct nexus and a contract between the client and the eligible Indian unit; deputation of technical manpower abroad for software work is similarly eligible when contractually engaged and conditions are met. Multiple SOWs under an MSA are permissible with SOW prevailing; Engineering and Design includes embedded R&D; slump-sale, SEZ relocation or setting up new units do not automatically defeat benefits, and separate books are not legally required though unit-level details may be sought.

General anti-avoidance rule: commencement deferred and substantive procedural safeguards added to govern tax avoidance assessments.
Government decisions implement GAAR with safeguards: the main purpose test for impermissible avoidance; a reasoned show cause notice and opportunity to rebut before invocation; consolidation into a single definition of connected person; revised Approving Panel with a judicial Chair whose directions bind both assessee and tax authorities; consideration limited to the impermissible part of arrangements; grandfathering of pre-existing investments; carve-outs for certain FII and non-resident investors; a monetary threshold to attract GAAR; retention and strengthening of advance rulings; auditor reporting requirements; and deferment of GAAR's commencement to April 1, 2016.

General Anti-Avoidance Rules recommendations narrow GAAR scope, add safeguards, and defer implementation for greater certainty.
General Anti-Avoidance Rules under the Income-tax Act were examined with recommendations to confine GAAR to abusive, contrived and artificial arrangements, to require the main purpose of obtaining tax benefit, and to define commercial substance by material effect on business risks or net cash flows. The Committee also proposed deferral of implementation, grandfathering of existing investments, a monetary threshold, restriction of connected person, exclusion where specific anti-avoidance rules or treaty limitation-of-benefits provisions apply, and procedural safeguards through a permanent Approving Panel, prescribed forms, time limits, and detailed Revenue reasons.

Video conferencing hearings permitted for tax appeals enabling remote E Bench proceedings with specified notice, filing and record requirements.
Hearing of income tax appeals may be conducted by video conferencing (E Court) with Members nominated to sit at E Benches; the Original Bench (OB) remains the bench of record and the remote forum is the E Bench (EB). Notices will specify OB and EB and enclose a registry note; parties may opt out within one week by prescribed intimation. Files are duplicated and sent to EB with a copy retained at OB; paper books must be filed in advance, loose documents are not permitted without bench permission, Bench Clerks will make simultaneous order entries, and orders signed by Members will be uploaded the same day.