Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Penalty immunity under the Direct Tax Vivad Se Vishwas Scheme does not extend to an independent penalty for failure to obtain a statutory tax audit merely because related quantum additions were settled. The penalty issue remains separately examinable. For futures and options transactions, tax-audit applicability depends on evidence establishing the transaction nature and turnover computation under the ICAI Guidance Note. Where the record does not show whether transactions were futures and options or delivery-based, the tax-audit requirement and consequential penalty require factual verification by the Assessing Officer after the taxpayer provides supporting particulars.
Penalty immunity under the Direct Tax Vivad Se Vishwas Scheme does not extend to an independent penalty for failure to obtain a statutory tax audit merely because related quantum additions were settled. The penalty issue remains separately examinable. For futures and options transactions, tax-audit applicability depends on evidence establishing the transaction nature and turnover computation under the ICAI Guidance Note. Where the record does not show whether transactions were futures and options or delivery-based, the tax-audit requirement and consequential penalty require factual verification by the Assessing Officer after the taxpayer provides supporting particulars.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
