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 CBDT's Income-tax (Sixth Amendment) Rules, 2025 expands safe harbour provisions for international transactions. The definition of "core auto components" under Rule 10TA now includes lithium ion batteries for electric/hybrid vehicles. Rule 10TD increases the monetary threshold for eligible international transactions from two crore to three crore rupees across multiple categories. The applicability period for safe harbour provisions has been extended to include assessment years 2025-26 and 2026-27. Rule 10TE now specifies that applications under Rule 10TD are valid for one assessment year. These amendments aim to modernize transfer pricing regulations to accommodate emerging technologies and provide greater taxpayer certainty.
The CBDT's Income-tax (Sixth Amendment) Rules, 2025 expands safe harbour provisions for international transactions. The definition of "core auto components" under Rule 10TA now includes lithium ion batteries for electric/hybrid vehicles. Rule 10TD increases the monetary threshold for eligible international transactions from two crore to three crore rupees across multiple categories. The applicability period for safe harbour provisions has been extended to include assessment years 2025-26 and 2026-27. Rule 10TE now specifies that applications under Rule 10TD are valid for one assessment year. These amendments aim to modernize transfer pricing regulations to accommodate emerging technologies and provide greater taxpayer certainty.
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