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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The Finance Bill 2025 introduces key changes to income tax provisions focusing on crypto-asset reporting, loss carry-forward in amalgamations, and extended timelines for various tax procedures. Major outcomes include: Reporting entities must furnish prescribed crypto-asset transaction information to tax authorities as India implements the Crypto-Asset Reporting Framework (CARF). Loss carry-forward in amalgamations is limited to 8 years from first occurrence rather than merger date for amalgamations after April 1, 2025. Updated returns filing timeline extended from 24 to 48 months with graduated additional tax rates of 60-70%. Self-occupied property taxation simplified by relaxing occupancy conditions. Penalty impositions shifted from Joint Commissioner to AO with approval requirements. Time limits rationalized for assessment completion, document retention, and penalty orders. The amendments aim to enhance voluntary compliance, reduce litigation, and align with international reporting standards while providing clarity on procedural timelines and administrative processes.
The Finance Bill 2025 introduces key changes to income tax provisions focusing on crypto-asset reporting, loss carry-forward in amalgamations, and extended timelines for various tax procedures. Major outcomes include: Reporting entities must furnish prescribed crypto-asset transaction information to tax authorities as India implements the Crypto-Asset Reporting Framework (CARF). Loss carry-forward in amalgamations is limited to 8 years from first occurrence rather than merger date for amalgamations after April 1, 2025. Updated returns filing timeline extended from 24 to 48 months with graduated additional tax rates of 60-70%. Self-occupied property taxation simplified by relaxing occupancy conditions. Penalty impositions shifted from Joint Commissioner to AO with approval requirements. Time limits rationalized for assessment completion, document retention, and penalty orders. The amendments aim to enhance voluntary compliance, reduce litigation, and align with international reporting standards while providing clarity on procedural timelines and administrative processes.
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