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...
The Direct Tax Vivad se Vishwas Scheme, 2024 (DTVSV Scheme) provides for resolution of pending income tax litigation. Key clarifications are: Appeals pending as on 22.07.2024, even if subsequently disposed, are eligible. Cases with prosecution instituted before declaration filing are ineligible. Set-aside appeals to ITAT/CIT(A)/DRP are eligible. Credit for taxes paid against disputed demands is available. For deductees availing the scheme, deductors are relieved from liability except interest and can claim expense deduction. The scheme applies to the full dispute, not partial issues. The designated authority can rectify patent errors. Foreign entities can file through representative assessees. Secondary adjustment u/s 92CE applies for transfer pricing cases after settling primary adjustments.
The Direct Tax Vivad se Vishwas Scheme, 2024 (DTVSV Scheme) provides for resolution of pending income tax litigation. Key clarifications are: Appeals pending as on 22.07.2024, even if subsequently disposed, are eligible. Cases with prosecution instituted before declaration filing are ineligible. Set-aside appeals to ITAT/CIT(A)/DRP are eligible. Credit for taxes paid against disputed demands is available. For deductees availing the scheme, deductors are relieved from liability except interest and can claim expense deduction. The scheme applies to the full dispute, not partial issues. The designated authority can rectify patent errors. Foreign entities can file through representative assessees. Secondary adjustment u/s 92CE applies for transfer pricing cases after settling primary adjustments.
Note: It is a system-generated summary and is for quick reference only.
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