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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The Finance Bill, 2025 proposes several amendments to the Income-tax Act, 1961, including modifications to Section 9A to remove indirect participation requirements for eligible investment funds, restoring the Central Government's power to modify conditions under Section 9A(8A), and clarifying Section 44BBD's presumptive taxation scheme for non-residents. Additional amendments include replacing "IFSC insurance intermediary" with "IFSC insurance offices" in Section 10(10D), expanding the definition of "resultant fund" to include Retail Schemes and ETFs, extending tax exemptions under Section 10(4E) to OTC derivatives, and broadening the definition of "capital asset" to include securities held by Category I and II AIFs. Chapter XIV-B has been revised to focus on assessing undisclosed income rather than total income in search cases.
The Finance Bill, 2025 proposes several amendments to the Income-tax Act, 1961, including modifications to Section 9A to remove indirect participation requirements for eligible investment funds, restoring the Central Government's power to modify conditions under Section 9A(8A), and clarifying Section 44BBD's presumptive taxation scheme for non-residents. Additional amendments include replacing "IFSC insurance intermediary" with "IFSC insurance offices" in Section 10(10D), expanding the definition of "resultant fund" to include Retail Schemes and ETFs, extending tax exemptions under Section 10(4E) to OTC derivatives, and broadening the definition of "capital asset" to include securities held by Category I and II AIFs. Chapter XIV-B has been revised to focus on assessing undisclosed income rather than total income in search cases.
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