Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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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