Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Tax-residency relief for Indian seafarers unable to remain outside India during the COVID-19 pandemic was sought through quashing CBDT Circular No. 11 of 2020 and adoption of a compassionate tax policy. The proposed policy would grant at least sixty days' exemption to seafarers who spent more than 182 days in India during a financial year. Representations were directed to receive sympathetic consideration, with an appropriate decision requested within four weeks, without examination of merits.
Tax-residency relief for Indian seafarers unable to remain outside India during the COVID-19 pandemic was sought through quashing CBDT Circular No. 11 of 2020 and adoption of a compassionate tax policy. The proposed policy would grant at least sixty days' exemption to seafarers who spent more than 182 days in India during a financial year. Representations were directed to receive sympathetic consideration, with an appropriate decision requested within four weeks, without examination of merits.
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TaxTMI 
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