Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Employee conflict disclosures and investment restrictions expand with new recusal duties, post-employment limits, and compliance reporting requirement...
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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