Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The existing provisions of section 230(1A) of the Income-tax Act, 1961, require obtaining a tax clearance certificate from income-tax authorities before leaving India, confirming no outstanding liabilities under specified Acts. To include liabilities under the Black Money Act, 2015, it is proposed to insert a reference to the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 in section 230(1A) for obtaining the tax clearance certificate. This amendment will take effect from October 1, 2024.
The existing provisions of section 230(1A) of the Income-tax Act, 1961, require obtaining a tax clearance certificate from income-tax authorities before leaving India, confirming no outstanding liabilities under specified Acts. To include liabilities under the Black Money Act, 2015, it is proposed to insert a reference to the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 in section 230(1A) for obtaining the tax clearance certificate. This amendment will take effect from October 1, 2024.
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