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 Ministry of Finance issued Notification No. 69/2025 under section 90 of the Income-tax Act, 1961, giving effect to the Protocol amending the Double Taxation Avoidance Agreement between India and Oman. The Protocol, signed at Muscat on 27 January 2025, entered into force on 28 May 2025. Key amendments include reducing withholding tax rates on royalties and technical fees from 15% to 10%, introducing anti-treaty shopping provisions, adding non-discrimination clauses, enhancing exchange of information mechanisms, and establishing mutual assistance in tax collection procedures. The Protocol provisions apply to income derived in fiscal years beginning on or after 1 April following the Protocol's effective date in India, and for tax years following the effective date in Oman.
The Ministry of Finance issued Notification No. 69/2025 under section 90 of the Income-tax Act, 1961, giving effect to the Protocol amending the Double Taxation Avoidance Agreement between India and Oman. The Protocol, signed at Muscat on 27 January 2025, entered into force on 28 May 2025. Key amendments include reducing withholding tax rates on royalties and technical fees from 15% to 10%, introducing anti-treaty shopping provisions, adding non-discrimination clauses, enhancing exchange of information mechanisms, and establishing mutual assistance in tax collection procedures. The Protocol provisions apply to income derived in fiscal years beginning on or after 1 April following the Protocol's effective date in India, and for tax years following the effective date in Oman.
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