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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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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