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 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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