Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Certificate under Section 195 was ordered rectified: a previously issued 5.25% certificate is directed to be treated as a Nil rate certificate and the competent authority must issue an amended Nil rate certificate within seven days on production of this order. Further directions require future Nil rate certificates for FY 2025 26 and subsequent years to be issued within 30 days of application, subject to a recorded finding that the applicant has a Permanent Establishment in India; such an adverse finding requires prior notice. Applicants must make full and true disclosure in annual applications.
Certificate under Section 195 was ordered rectified: a previously issued 5.25% certificate is directed to be treated as a Nil rate certificate and the competent authority must issue an amended Nil rate certificate within seven days on production of this order. Further directions require future Nil rate certificates for FY 2025 26 and subsequent years to be issued within 30 days of application, subject to a recorded finding that the applicant has a Permanent Establishment in India; such an adverse finding requires prior notice. Applicants must make full and true disclosure in annual applications.
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