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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A parliamentary Select Committee reviewed the Income-Tax Bill, 2025, recommending multiple amendments to align definitions, clarify provisions, and ensure consistency with prior laws. Key suggestions included refining definitions of "capital asset," "infrastructure capital company," and "parent company"; clarifying deductions related to house property, scientific research, and employer pension contributions; and addressing ambiguities in carry forward of losses, tax rebates, and non-profit organization provisions. The Committee emphasized reinstating certain safeguards in anti-avoidance rules, expanding electronic payment acceptance to professionals, and specifying jurisdictional limits for evidence powers. It also proposed amendments to penalty discretion, valuation qualifications, and timelines for non-resident compliance. The Committee sought to remove inconsistencies with the repealed Income-tax Act, 1961, and recommended drafting corrections to enhance clarity, prevent litigation, and maintain fairness in tax administration. The report was presented to the Lok Sabha on July 21, 2025.
A parliamentary Select Committee reviewed the Income-Tax Bill, 2025, recommending multiple amendments to align definitions, clarify provisions, and ensure consistency with prior laws. Key suggestions included refining definitions of "capital asset," "infrastructure capital company," and "parent company"; clarifying deductions related to house property, scientific research, and employer pension contributions; and addressing ambiguities in carry forward of losses, tax rebates, and non-profit organization provisions. The Committee emphasized reinstating certain safeguards in anti-avoidance rules, expanding electronic payment acceptance to professionals, and specifying jurisdictional limits for evidence powers. It also proposed amendments to penalty discretion, valuation qualifications, and timelines for non-resident compliance. The Committee sought to remove inconsistencies with the repealed Income-tax Act, 1961, and recommended drafting corrections to enhance clarity, prevent litigation, and maintain fairness in tax administration. The report was presented to the Lok Sabha on July 21, 2025.
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