Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The CBDT issued a notification amending Income-tax Rules, 1962, specifically Form 27EQ, to expand Tax Collection at Source (TCS) provisions under section 206C. The amendment introduces new categories for TCS collection, including sales of luxury and specialized items such as wrist watches, art pieces, collectibles, yachts, sunglasses, bags, shoes, sportswear, home theatre systems, and horses for racing. Each category is assigned a specific code (MA through MJ) for reporting purposes. The amendment becomes effective from the date of publication in the Official Gazette, enhancing tax collection mechanisms for high-value and niche product transactions.
The CBDT issued a notification amending Income-tax Rules, 1962, specifically Form 27EQ, to expand Tax Collection at Source (TCS) provisions under section 206C. The amendment introduces new categories for TCS collection, including sales of luxury and specialized items such as wrist watches, art pieces, collectibles, yachts, sunglasses, bags, shoes, sportswear, home theatre systems, and horses for racing. Each category is assigned a specific code (MA through MJ) for reporting purposes. The amendment becomes effective from the date of publication in the Official Gazette, enhancing tax collection mechanisms for high-value and niche product transactions.
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