Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Section 276B of the Income Tax Act is being amended to provide exemption from prosecution for failure to pay tax deducted at source (TDS) if the payment is made by the due date for filing the TDS statement for that quarter. Currently, non-payment of TDS attracts rigorous imprisonment of 3 months to 7 years and fine. The amendment decriminalizes the offence if TDS is paid by the statement filing due date. The amendment takes effect from October 1, 2024.
Section 276B of the Income Tax Act is being amended to provide exemption from prosecution for failure to pay tax deducted at source (TDS) if the payment is made by the due date for filing the TDS statement for that quarter. Currently, non-payment of TDS attracts rigorous imprisonment of 3 months to 7 years and fine. The amendment decriminalizes the offence if TDS is paid by the statement filing due date. The amendment takes effect from October 1, 2024.
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