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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...
Proposed amendment to Explanation 3 of Section 37(1) to disallow deduction for expenditure incurred by an assessee to settle proceedings initiated in relation to a contravention under any law, as notified by the Central Government. The amendment aims to widen the tax base and promote anti-avoidance by disallowing settlement amounts paid for contraventions as business expenses. Effective from April 1, 2025, applicable from assessment year 2025-2026 onwards.
Proposed amendment to Explanation 3 of Section 37(1) to disallow deduction for expenditure incurred by an assessee to settle proceedings initiated in relation to a contravention under any law, as notified by the Central Government. The amendment aims to widen the tax base and promote anti-avoidance by disallowing settlement amounts paid for contraventions as business expenses. Effective from April 1, 2025, applicable from assessment year 2025-2026 onwards.
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