Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Sovereign Wealth Funds seeking exemption under Schedule V of the Income-tax Act, 2025 must file Form I for notification and then file quarterly Form II statements for each investment within one month from quarter-end, together with return of income and audit report. SWFs already notified under the 1961 Act need not file a fresh Form I, but must still submit quarterly Form II statements. CBDT also requires the prescribed data structure, verification standards and security protocols for the forms. The circular takes effect from 1 April 2026 and applies from tax year 2026-27 onward.
Sovereign Wealth Funds seeking exemption under Schedule V of the Income-tax Act, 2025 must file Form I for notification and then file quarterly Form II statements for each investment within one month from quarter-end, together with return of income and audit report. SWFs already notified under the 1961 Act need not file a fresh Form I, but must still submit quarterly Form II statements. CBDT also requires the prescribed data structure, verification standards and security protocols for the forms. The circular takes effect from 1 April 2026 and applies from tax year 2026-27 onward.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
