Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Foreign Assets of Small Taxpayers Disclosure Scheme Rules, 2026 establish electronic procedures for declaring specified undisclosed foreign assets and income. Fair market value is prescribed by asset class, generally using the higher of acquisition cost and valuation-date market value, with indexed cost deemed applicable where valuation is unavailable; special rules apply to bank accounts, transferred assets, reinvestment chains, partnership interests and currency conversion. Declarations in Form 1 are limited by separate aggregate-value thresholds for undisclosed assets and income, and for previously taxed or non-resident-acquired foreign assets not disclosed after becoming resident. Payment, electronic intimation and certification are made through Forms 2-4; delayed payment attracts interest, while non-payment within the permitted period voids the declaration. Valid certification grants the specified tax, penalty and prosecution immunity.
Foreign Assets of Small Taxpayers Disclosure Scheme Rules, 2026 establish electronic procedures for declaring specified undisclosed foreign assets and income. Fair market value is prescribed by asset class, generally using the higher of acquisition cost and valuation-date market value, with indexed cost deemed applicable where valuation is unavailable; special rules apply to bank accounts, transferred assets, reinvestment chains, partnership interests and currency conversion. Declarations in Form 1 are limited by separate aggregate-value thresholds for undisclosed assets and income, and for previously taxed or non-resident-acquired foreign assets not disclosed after becoming resident. Payment, electronic intimation and certification are made through Forms 2-4; delayed payment attracts interest, while non-payment within the permitted period voids the declaration. Valid certification grants the specified tax, penalty and prosecution immunity.
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