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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 Central Government issued Notification No. 67/2025 under sections 197A and 80LA of the Income Tax Act 1961, exempting specified IFSC units from tax deduction at source on various payments. The exemption applies to seven categories of IFSC entities including BATF service providers, broker-dealers, finance companies, fund management entities, recognised clearing corporations, depositories, and stock exchanges for specific payment types under sections 194A, 194C, 194H, 194I, and 194J. Payees must furnish Form No. 1 declaration for ten consecutive assessment years claiming section 80LA deduction. The notification becomes effective July 1, 2025, promoting IFSC operations through TDS relief.
The Central Government issued Notification No. 67/2025 under sections 197A and 80LA of the Income Tax Act 1961, exempting specified IFSC units from tax deduction at source on various payments. The exemption applies to seven categories of IFSC entities including BATF service providers, broker-dealers, finance companies, fund management entities, recognised clearing corporations, depositories, and stock exchanges for specific payment types under sections 194A, 194C, 194H, 194I, and 194J. Payees must furnish Form No. 1 declaration for ten consecutive assessment years claiming section 80LA deduction. The notification becomes effective July 1, 2025, promoting IFSC operations through TDS relief.
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