Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
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...
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Reporting persons or entities receiving Form No. 97 declarations for transactions covered by rule 159 must furnish Form No. 98 electronically by 31 October for declarations received by 30 September and by 30 April of the following financial year for declarations received by 31 March. They must register on the Reporting Portal, obtain an ITDREIN, and upload digitally signed statements through the principal officer's credentials. Existing Form No. 61 registrants may use their existing ITDREIN and principal officer. Inaccuracies and Data Quality Report defects require correction statements, while inadvertently filed reports may be removed through deletion statements. Entities must maintain information-security, archival and retrieval procedures. The procedure applies from 15 September 2026; earlier-year reporting remains under Form No. 61.
Reporting persons or entities receiving Form No. 97 declarations for transactions covered by rule 159 must furnish Form No. 98 electronically by 31 October for declarations received by 30 September and by 30 April of the following financial year for declarations received by 31 March. They must register on the Reporting Portal, obtain an ITDREIN, and upload digitally signed statements through the principal officer's credentials. Existing Form No. 61 registrants may use their existing ITDREIN and principal officer. Inaccuracies and Data Quality Report defects require correction statements, while inadvertently filed reports may be removed through deletion statements. Entities must maintain information-security, archival and retrieval procedures. The procedure applies from 15 September 2026; earlier-year reporting remains under Form No. 61.
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