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...
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.
Note: It is a system-generated summary and is for quick reference only.
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