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...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Penalty notices must specify whether the alleged default is concealment of income or furnishing inaccurate particulars; retaining both alternatives without identifying the charge indicates non-application of mind and may deny an adequate opportunity to respond. The notes also address penalties for delayed employees' provident fund contributions and book-profit adjustments, stating that a debatable disallowance or mere rejection of a claim does not itself establish concealment, inaccurate particulars, or wilful tax evasion. An excess weighted research deduction claimed on disclosed material before subsequent approval may be bona fide. Penalty for under-reporting also requires identification and communication of the applicable statutory circumstance, failing which proceedings breach natural justice.
Penalty notices must specify whether the alleged default is concealment of income or furnishing inaccurate particulars; retaining both alternatives without identifying the charge indicates non-application of mind and may deny an adequate opportunity to respond. The notes also address penalties for delayed employees' provident fund contributions and book-profit adjustments, stating that a debatable disallowance or mere rejection of a claim does not itself establish concealment, inaccurate particulars, or wilful tax evasion. An excess weighted research deduction claimed on disclosed material before subsequent approval may be bona fide. Penalty for under-reporting also requires identification and communication of the applicable statutory circumstance, failing which proceedings breach natural justice.
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