Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
The India-Japan Memorandum of Understanding for assistance in collection of taxes under Article 26A is notified for effect in India. The memorandum, signed at Tokyo and New Delhi in 2025, applies to requests for collection of taxes made after the later date of signature by the two competent authorities, namely 8 July 2025. The notification gives effect in the Union of India to all provisions of the memorandum as set out in the annexure, thereby operationalising the agreed framework for tax-collection assistance between the two countries.
The India-Japan Memorandum of Understanding for assistance in collection of taxes under Article 26A is notified for effect in India. The memorandum, signed at Tokyo and New Delhi in 2025, applies to requests for collection of taxes made after the later date of signature by the two competent authorities, namely 8 July 2025. The notification gives effect in the Union of India to all provisions of the memorandum as set out in the annexure, thereby operationalising the agreed framework for tax-collection assistance between the two countries.
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