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Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
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India notifies the amending Protocol to the India-Brazil tax treaty, which entered into force on 18 October 2025 and is given effect in India under section 90 of the Income-tax Act. The amendments update treaty provisions on residence, permanent establishment, shipping and air transport, dividends, interest, royalties, technical services, capital gains, employment income, artistes and sportspersons, pensions, relief from double taxation, non-discrimination, mutual agreement procedure, and treaty entitlement. The Protocol also introduces detailed anti-abuse rules, including qualified person tests, active business tests, ownership thresholds, principal purpose denial, and protection against treaty-shopping.
India notifies the amending Protocol to the India-Brazil tax treaty, which entered into force on 18 October 2025 and is given effect in India under section 90 of the Income-tax Act. The amendments update treaty provisions on residence, permanent establishment, shipping and air transport, dividends, interest, royalties, technical services, capital gains, employment income, artistes and sportspersons, pensions, relief from double taxation, non-discrimination, mutual agreement procedure, and treaty entitlement. The Protocol also introduces detailed anti-abuse rules, including qualified person tests, active business tests, ownership thresholds, principal purpose denial, and protection against treaty-shopping.
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