Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
The proposed amendments to income deemed to accrue or arise in India under the Income Tax Bill, 2025, introduce comprehensive modifications to existing provisions under ss 9 and 9A of ITA 1961. Key changes include expanded definition of business connection incorporating significant economic presence, detailed framework for digital economy taxation, and modified investment fund management provisions. The amendments align with OECD BEPS guidelines while introducing specific provisions for online advertising, data monetization, and digital services targeting Indian market. The revised framework modernizes India's international taxation approach, particularly addressing digital economy challenges. Notable implications include reassessment requirements for businesses' digital presence, enhanced scope of taxable income for non-residents, and modified compliance obligations for fund managers under the new regulatory structure.
The proposed amendments to income deemed to accrue or arise in India under the Income Tax Bill, 2025, introduce comprehensive modifications to existing provisions under ss 9 and 9A of ITA 1961. Key changes include expanded definition of business connection incorporating significant economic presence, detailed framework for digital economy taxation, and modified investment fund management provisions. The amendments align with OECD BEPS guidelines while introducing specific provisions for online advertising, data monetization, and digital services targeting Indian market. The revised framework modernizes India's international taxation approach, particularly addressing digital economy challenges. Notable implications include reassessment requirements for businesses' digital presence, enhanced scope of taxable income for non-residents, and modified compliance obligations for fund managers under the new regulatory structure.
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