Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
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: Section 47(iii) of the Income Tax Act, which exempts transfers of capital assets under gift, will or irrevocable trust from capital gains tax, is proposed to be amended. The amendment aims to limit the exemption to individuals and Hindu Undivided Families, effectively making such transfers by companies taxable. This move intends to curb tax avoidance and erosion of the tax base through gifting of shares by companies, which has been a litigated issue. The amendment will be effective from April 1, 2025, applicable for Assessment Year 2025-26 onwards.
Income Tax: Section 47(iii) of the Income Tax Act, which exempts transfers of capital assets under gift, will or irrevocable trust from capital gains tax, is proposed to be amended. The amendment aims to limit the exemption to individuals and Hindu Undivided Families, effectively making such transfers by companies taxable. This move intends to curb tax avoidance and erosion of the tax base through gifting of shares by companies, which has been a litigated issue. The amendment will be effective from April 1, 2025, applicable for Assessment Year 2025-26 onwards.
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