Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
A presumptive taxation regime is being introduced for non-resident cruise ship operators, deeming 20% of aggregate receipts as profits and gains from this business. Lease rentals paid by a company opting for this regime to a foreign company, if both are subsidiaries of the same holding company, will be exempt until assessment year 2030-31. Section 44B for presumptive taxation of non-resident shipping business will not apply to cruise ship operations. These amendments will be effective from April 1, 2025, applicable for assessment year 2025-26 onwards, to promote cruise shipping industry in India.
A presumptive taxation regime is being introduced for non-resident cruise ship operators, deeming 20% of aggregate receipts as profits and gains from this business. Lease rentals paid by a company opting for this regime to a foreign company, if both are subsidiaries of the same holding company, will be exempt until assessment year 2030-31. Section 44B for presumptive taxation of non-resident shipping business will not apply to cruise ship operations. These amendments will be effective from April 1, 2025, applicable for assessment year 2025-26 onwards, to promote cruise shipping industry in India.
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