Tax appeal allowed: AO exceeded s.144C DRP mandate by introducing new findings and recharacterising non-resident receipts as permanent establishment i...
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A central government notification gives effect to an Amending Protocol to a bilateral tax treaty between two States, entering into force 26 June 2025. The Protocol revises definitions (including "competent authority" and "criminal tax matters"), replaces the exchange-of-information article to broaden information sharing (including bank and ownership information) while preserving secrecy and legal limits, and replaces the assistance-in-collection article to permit mutual recovery and conservancy measures for revenue claims subject to domestic law and proportionality limits. Parties must notify completion of domestic procedures; criminal tax matters apply immediately and other amendments apply to taxable periods or tax charges arising on or after the entry-into-force date.
A central government notification gives effect to an Amending Protocol to a bilateral tax treaty between two States, entering into force 26 June 2025. The Protocol revises definitions (including "competent authority" and "criminal tax matters"), replaces the exchange-of-information article to broaden information sharing (including bank and ownership information) while preserving secrecy and legal limits, and replaces the assistance-in-collection article to permit mutual recovery and conservancy measures for revenue claims subject to domestic law and proportionality limits. Parties must notify completion of domestic procedures; criminal tax matters apply immediately and other amendments apply to taxable periods or tax charges arising on or after the entry-into-force date.
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