Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
No deduction of tax is required under section 393(1) on lease rent or supplemental lease rent paid to an IFSC unit leasing aircraft, provided the lessor furnishes the prescribed statement-cum-declaration in Form 1(N) and the lessee receives it. The exemption applies only for the twenty consecutive tax years declared by the lessor for which deduction under section 147 is opted; for any other year, tax must be deducted. The lessee must report all non-deducted payments in the tax deduction statement, and the notification applies from 1 April 2026. It also sets system and data-security responsibilities for the tax systems authority and defines aircraft, IFSC, and unit by reference to the Act and SEZ law.
No deduction of tax is required under section 393(1) on lease rent or supplemental lease rent paid to an IFSC unit leasing aircraft, provided the lessor furnishes the prescribed statement-cum-declaration in Form 1(N) and the lessee receives it. The exemption applies only for the twenty consecutive tax years declared by the lessor for which deduction under section 147 is opted; for any other year, tax must be deducted. The lessee must report all non-deducted payments in the tax deduction statement, and the notification applies from 1 April 2026. It also sets system and data-security responsibilities for the tax systems authority and defines aircraft, IFSC, and unit by reference to the Act and SEZ law.
Note: It is a system-generated summary and is for quick reference only.
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