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 CBDT has issued the Income-tax (Eighth Amendment) Rules, 2025, effective April 1, 2025, significantly modifying Form 3CD used for tax audit reports under Section 44AB. Key amendments include: insertion of Section 44BBC references; removal of obsolete deduction rows; addition of reporting requirements for settlement expenditures related to contraventions; comprehensive restructuring of MSME payment reporting requirements; modifications to Section 43B reporting; elimination of clauses 28 and 29; introduction of coded classifications for loan/deposit transactions with a detailed 12-category coding system; and new disclosure requirements for share buyback transactions, including amounts received and acquisition costs of shares bought back.
The CBDT has issued the Income-tax (Eighth Amendment) Rules, 2025, effective April 1, 2025, significantly modifying Form 3CD used for tax audit reports under Section 44AB. Key amendments include: insertion of Section 44BBC references; removal of obsolete deduction rows; addition of reporting requirements for settlement expenditures related to contraventions; comprehensive restructuring of MSME payment reporting requirements; modifications to Section 43B reporting; elimination of clauses 28 and 29; introduction of coded classifications for loan/deposit transactions with a detailed 12-category coding system; and new disclosure requirements for share buyback transactions, including amounts received and acquisition costs of shares bought back.
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