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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
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...
Income Tax: Rationalisation of provisions related to time-limit for completion of assessment, reassessment and recomputation. Proposed amendments: (i) Insertion of new sub-section (1B) to provide time-limit for assessment orders where return is filed pursuant to section 119(2)(b). (ii) Inclusion of reference to section 250 in sub-section (3) for time-limit to pass fresh assessment order. (iii) Amendment to sub-section (8) to provide timeline for revived assessment/reassessment proceedings due to annulment of block assessments under Chapter XIV-B. (iv) Amendment to Explanation 1(xii) to provide that date of limitation in search cases falls at month-end after exclusions. Consequential amendment to section 139 for returns filed pursuant to section 119(2)(b) order. Effective from 1st October 2024.
Income Tax: Rationalisation of provisions related to time-limit for completion of assessment, reassessment and recomputation. Proposed amendments: (i) Insertion of new sub-section (1B) to provide time-limit for assessment orders where return is filed pursuant to section 119(2)(b). (ii) Inclusion of reference to section 250 in sub-section (3) for time-limit to pass fresh assessment order. (iii) Amendment to sub-section (8) to provide timeline for revived assessment/reassessment proceedings due to annulment of block assessments under Chapter XIV-B. (iv) Amendment to Explanation 1(xii) to provide that date of limitation in search cases falls at month-end after exclusions. Consequential amendment to section 139 for returns filed pursuant to section 119(2)(b) order. Effective from 1st October 2024.
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