Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
CBDT clarifies the safe harbour regime for foreign companies selling raw diamonds in Special Notified Zones. 'Raw diamonds' must satisfy all rule 99(f) conditions simultaneously; sorted diamonds are excluded, and a Kimberley Process Certificate alone is insufficient. A foreign company declaring at least 4% profit under the regime is accepted at foreign-company tax rates with surcharge, but cannot claim deductions. Treaty-based tax credit, if any, depends on the applicable DTAA and domestic law of the home jurisdiction. The option is invalid if availed on incorrect or concealed facts. The assessee need not be incorporated in India, must itself carry on the business, TDS applies, and non-opted assessees remain taxable under the ordinary law and DTAA.
CBDT clarifies the safe harbour regime for foreign companies selling raw diamonds in Special Notified Zones. 'Raw diamonds' must satisfy all rule 99(f) conditions simultaneously; sorted diamonds are excluded, and a Kimberley Process Certificate alone is insufficient. A foreign company declaring at least 4% profit under the regime is accepted at foreign-company tax rates with surcharge, but cannot claim deductions. Treaty-based tax credit, if any, depends on the applicable DTAA and domestic law of the home jurisdiction. The option is invalid if availed on incorrect or concealed facts. The assessee need not be incorporated in India, must itself carry on the business, TDS applies, and non-opted assessees remain taxable under the ordinary law and DTAA.
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