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 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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