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Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The Income-tax (Twentieth Amendment) Rules, 2025, amend the Income-tax Rules, 1962, specifically rule 21AK, to include over-the-counter derivatives alongside offshore derivative instruments concerning income of non-residents. The amendment expands the scope to cover Foreign Portfolio Investors registered under SEBI regulations, treating them similarly to entities regulated by the International Financial Services Centres Authority. The changes clarify definitions related to transactions between purchasers and sellers and explicitly define "Foreign Portfolio Investor" as per SEBI regulations. These amendments aim to align tax provisions with current financial instruments and investor categories and came into effect upon publication in the Official Gazette.
The Income-tax (Twentieth Amendment) Rules, 2025, amend the Income-tax Rules, 1962, specifically rule 21AK, to include over-the-counter derivatives alongside offshore derivative instruments concerning income of non-residents. The amendment expands the scope to cover Foreign Portfolio Investors registered under SEBI regulations, treating them similarly to entities regulated by the International Financial Services Centres Authority. The changes clarify definitions related to transactions between purchasers and sellers and explicitly define "Foreign Portfolio Investor" as per SEBI regulations. These amendments aim to align tax provisions with current financial instruments and investor categories and came into effect upon publication in the Official Gazette.
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