Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The government notified entry into force of a bilateral agreement and protocol between the two Contracting States to avoid double taxation and prevent fiscal evasion, effective for income arising from the first day of the fiscal year following entry into force. The treaty covers taxes on income, defines residency, permanent establishment rules, and allocation of taxing rights; prescribes withholding limits (dividends 5%/10%, interest 10%, royalties/technical fees 10%), rules on business profits, capital gains, employment income, and exemptions for certain persons. It includes provisions on non-discrimination, mutual agreement procedure, exchange of information, assistance in collection, a principal-purpose anti-abuse rule, and termination mechanics.
The government notified entry into force of a bilateral agreement and protocol between the two Contracting States to avoid double taxation and prevent fiscal evasion, effective for income arising from the first day of the fiscal year following entry into force. The treaty covers taxes on income, defines residency, permanent establishment rules, and allocation of taxing rights; prescribes withholding limits (dividends 5%/10%, interest 10%, royalties/technical fees 10%), rules on business profits, capital gains, employment income, and exemptions for certain persons. It includes provisions on non-discrimination, mutual agreement procedure, exchange of information, assistance in collection, a principal-purpose anti-abuse rule, and termination mechanics.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
