Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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