Loading...

Top
Help
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback

Contact Us At :

E-mail: [email protected]

Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
  6. Text Search
  7. The system will try to fetch results that contains ALL your words.
  8. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
  9. Text Search
Add to...
You have not created any category. Kindly create one to bookmark this item!
Create New Category
Hide
Title :
Description :
❮❮ Hide
Default View
Expand ❯❯
Close ✕
🔎 TMI Notes - Adv. Search
TEXT

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In
Main Text + AI Text
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws----
  • ---- All Laws----
  • Benami Property
  • Bill
  • Central Excise
  • Companies Law
  • Customs
  • DGFT
  • FEMA
  • GST
  • GST - States
  • IBC
  • Income Tax
  • Indian Laws
  • Money Laundering
  • SEBI
  • SEZ
  • Service Tax
  • VAT / Sales Tax
Types:
---- All Types ----
  • ---- All Types ----
  • Act Rules
  • Case Laws
  • Circulars
  • Manuals
  • News
  • Notifications
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
    Case Laws Income Tax
    Form No.10B & Section 119(2)(b): Condonation of Delay in Tax Exemption Claims: Principles, Precedent...
    Case Laws Income Tax
    Section 195, DTAAs and Software Licences: A Practical Framework for Withholding Tax
    Case Laws Income Tax
    Section 263 Revisited: Jurisdictional Boundaries Where AO Takes a Plausible View on 80G Claims
    Case Laws Income Tax
    Section 11(3) After Finance Act, 2022: Utilization of Accumulated Income - Deemed Income, Vesting an...
    Case Laws Income Tax
    When Can an ITAT Reopen a Decision? Distinguishing Prior Binding Precedent from Subsequent Case-Law
    Case Laws Income Tax
    Faceless Assessment and Jurisdiction: Reconciling JAO Roles with NFAC u/ss 144B & 151A (JAO / FAO)
    Act Rules Income Tax
    Comparison of SCHEDULE XVI "PERMITTED MODES OF INVESTMENT OR DEPOSITS" between the Income-Tax Act, 2...
    Act Rules Income Tax
    Comparison of SCHEDULE-XV "DEDUCTION IN RESPECT OF LIFE INSURANCE PREMIA, CONTRIBUTION TO PROVIDENT ...
    Act Rules Income Tax
    Comparison of SCHEDULE XIV "INSURANCE BUSINESS" between the Income-Tax Act, 2025 (as passed) and the...
    Act Rules Income Tax
    Comparison of SCHEDULE XI "RECOGNISED PROVIDENT FUNDS" between the Income-Tax Act, 2025 (as passed) ...
    Act Rules Income Tax
    Comparison of SCHEDULE X "DEDUCTION FOR SITE RESTORATION FUND FOR COMPUTING INCOME UNDER THE HEAD "P...
    Act Rules Income Tax
    Comparison of SCHEDULE IX "DEDUCTION FOR TEA DEVELOPMENT ACCOUNT, COFFEE DEVELOPMENT ACCOUNT AND RUB...
    Act Rules Income Tax
    Comparison of SCHEDULE VIII "INCOME NOT TO BE INCLUDED IN THE TOTAL INCOME OF POLITICAL PARTIES AND ...
    Act Rules Income Tax
    Comparison of SCHEDULE VII "PERSONS EXEMPT FROM TAX" between the Income-Tax Act, 2025 (as passed) an...
    Act Rules Income Tax
    Comparison of SCHEDULE VI "INCOME NOT TO BE INCLUDED IN TOTAL INCOME OF CERTAIN ELIGIBLE PERSONS IN ...
    Act Rules Income Tax
    Comparison of SCHEDULE V "INCOME NOT TO BE INCLUDED IN TOTAL INCOME OF CERTAIN ELIGIBLE PERSONS INCL...
    Act Rules Income Tax
    Comparison of SCHEDULE IV "INCOME NOT TO BE INCLUDED IN TOTAL INCOME OF ELIGIBLE NON-RESIDENTS, FORE...
    Act Rules Income Tax
    Comparison of SCHEDULE III "INCOME NOT TO BE INCLUDED IN TOTAL INCOME OF ELIGIBLE PERSONS" between t...
    Act Rules Income Tax
    Comparison of SCHEDULE II "INCOME NOT TO BE INCLUDED IN TOTAL INCOME" between the Income-Tax Act, 20...
    Act Rules Income Tax
    Comparison of SCHEDULE I "CONDITIONS FOR CERTAIN ACTIVITIES NOT TO CONSTITUTE BUSINESS CONNECTION IN...
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Notes
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries
Case Laws Income Tax
Show AI Summary
Condonation of delay in tax exemption claims should favor substantive rights over mere technical filing defects when bona fide.
Equitable application of the Condonation Power requires authorities to admit late Form No.10B filings when short delays or credible explanations would otherwise strip claimants of substantive exemption rights; procedural defects such as digital-signature technicalities must be tested against documentary e-filing evidence and substantial compliance, while administrative safeguards permit subsequent verification of the audit report.
Case Laws Income Tax
Show AI Summary
Royalty characterisation for software determines withholding-non exclusive copies/licenses generally not subject to TDS unless income is chargeable.
Payments for off the shelf/shrink wrapped software or hardware embedded software that constitute a resale of a copyrighted article or a grant of a non exclusive, restricted licence for internal use do not ordinarily constitute royalty under section 9(1)(vi) or typical DTAA provisions; withholding under section 195 arises only where the non resident's receipts are chargeable to tax in India (e.g., due to a PE or transfer of substantive copyright rights), and retrospective domestic amendments cannot be used to impose past withholding obligations on payors who lacked notice of the expanded definition.
Case Laws Income Tax
Show AI Summary
Revisional jurisdiction cannot overturn a plausible assessment on charitable deductions where donation conditions are met.
Tribunals held that Explanation 2 limiting CSR expenditure as a business deduction operates within the business income chapter and does not ipso facto bar claims under the donations regime; specific statutory exceptions indicate Parliament's choice to restrict only certain items. A mandatory CSR outlay does not automatically negate donation character where there is no material return, provided donee approval and documentary evidence are established. On revisional power, section 263 cannot be invoked to overturn an assessing officer's tenable, precedent backed view where enquiries were made; revision is justified only if the AO's conclusion is legally untenable or there was no inquiry.
Case Laws Income Tax
Show AI Summary
Accumulated trust income: Tribunal rulings treat the 2022 amendment as prospective, preserving the prior six year utilisation window.
Two Tribunal benches held that the Finance Act, 2022 amendment to the accumulation provision is prospective; accumulations made before 1 April 2022 remain governed by the prior law including the additional one year grace, and utilisation within that six year window cannot be taxed for AY 2023 24. The Tribunals relied on the presumption against retrospectivity, the Finance Bill memorandum stating an effective date of 1 April 2023, and fairness doctrines to conclude Parliament did not intend to curtail vested rights retroactively.
Case Laws Income Tax
Show AI Summary
Tribunal recall power limited: later judicial overruling alone cannot reopen finalized tax orders under review rules.
The tribunal's power to amend is limited to rectifying a mistake apparent from the record existing at the time of the original order or to taking into account contemporaneous binding precedent not placed before it; a subsequent overruling or clarification by a superior court cannot alone justify recall, in light of the explanatory bar in Order XLVII Rule 1 CPC and related authorities.
Case Laws Income Tax
Show AI Summary
Concurrent jurisdiction between JAO and faceless authorities affirmed; JAO may initiate reassessment followed by faceless assessment.
The faceless scheme and RMS produce information that may be surfaced to the JAO, permitting the JAO to conduct the pre-notice inquiry and form satisfaction to issue a notice initiating reassessment; thereafter records may be transmitted for faceless assessment via automated allocation, embodying a two-stage model that preserves both JAO initiation authority and central faceless assessment.
Act Rules Income Tax
Show AI Summary
Permitted Modes of Investment: clarifies eligible instruments for registered non profit funds under section 350 compliance.
The schedule lists closed, enumerated permitted modes of investment for monies under section 350, privileging government backed and regulated instruments, specified sectoral debt and equity, deposits with public authorities, and notified schemes; it defines key terms (e.g., long term finance as five year minimum) and preserves transitional and historical exceptions including a one year short term holding rule for non specified assets and preservation of corpus assets held on specified historical dates.
Act Rules Income Tax
Show AI Summary
Deduction for specified payments: qualifying contributions allowed, but breach or early disposal triggers recapture of previously allowed deductions.
Schedule XV lists payments that qualify for deduction under section 123-notably life insurance premia subject to quantitative ceilings by policy issue date and disability status, specified provident/pension/superannuation contributions, notified securities and mutual fund units, certain term deposits and housing finance repayments-and sets withdrawal and recapture rules whereby surrender, premature transfer, early withdrawal or sale within holding periods causes previously allowed deductions to be treated as income; definitions and eligibility depend on cross-references and delegated notifications.
Act Rules Income Tax
Show AI Summary
Life insurance taxable profit computed by annual average of actuarial surplus, separate from other business for tax purposes.
Life insurance taxable profit must be computed separately as the annual average of actuarial surplus from statutory valuations excluding earlier inter-valuation surplus/deficits, with specified add-backs; non-life taxable income is the profit before tax and appropriations per statutory accounts subject to enumerated tax adjustments, and non-resident branch profits may be allocated by India-premium proportion absent suitably reliable alternative data.
Act Rules Income Tax
Show AI Summary
Recognition conditions for provident funds determine tax treatment and trustee obligations, with investment limits tied to securities definitions.
Schedule XI conditions tax-favourable treatment of recognised provident, superannuation and gratuity funds on structural and operational criteria (trust form, vesting, non-revocability, employee coverage, permitted assets and payment rules); recognition/approval is discretionary and revocable; failures attract inclusion of accumulated balances or contributions in employee income and procedural obligations such as TDS; trustees face record-keeping, reporting and potential liability, while the Board may make rules subject to statutory limits and section 534 oversight.
Act Rules Income Tax
Show AI Summary
Deduction for site restoration funds: designated SBI deposits allow capped tax relief but trigger deeming on improper use.
A deduction permits upstream petroleum and natural gas taxpayers to deduct amounts deposited in designated site restoration accounts held with the State Bank of India, limited to the lesser of actual deposits or 20% of business profits before the deduction; deposits and interest are treated as account balance, withdrawals are restricted to scheme permitted uses, and improper utilisation or account closure triggers deeming provisions or disallowance, with an eight year clawback on asset sales subject to narrow exceptions.
Act Rules Income Tax
Show AI Summary
Deduction for development account deposits: allowable up to 40% of profits, subject to strict deposit, audit and claw back rules.
The Schedule allows growers and manufacturers of tea, coffee and rubber to deduct deposits into prescribed development accounts up to the lesser of actual deposits or 40% of business profits, subject to carrying on the specified business in India, depositing funds in specified special or deposit accounts under board or National Bank schemes, and furnishing a prescribed audited report by the specified date; unauthorised withdrawals or use for specified articles are deemed taxable and assets acquired from such funds are subject to claw back if sold or transferred within eight years.
Act Rules Income Tax
Show AI Summary
Income exclusion for political funding conditioned on transparency, recordkeeping, prescribed receipt modes and distribution obligations.
The Schedule excludes specified receipts from total income of eligible political parties and electoral trusts-covering property income, other sources, capital gains and voluntary contributions for registered parties, and voluntary contributions for electoral trusts-conditional on maintenance of books, audited accounts, prescribed filing of returns, donor identification for significant contributions, prescribed modes of receipt for larger donations, distribution obligations for electoral trusts, and cross-referenced compliance with electoral and banking statutory provisions.
Act Rules Income Tax
Show AI Summary
Persons exempt from tax: categories qualify for total income exclusion subject to approvals, notifications and prescribed conditions.
Schedule VII lists 48 categories of persons whose total income is exempt from income tax subject to specified conditions: approvals by tax/regulatory authorities, Central Government notifications, prescribed financing thresholds to qualify as wholly or substantially government financed, and defined time limited exemptions for certain financing institutions. The Schedule relies on six Notes for statutory definitions and cross references other income tax provisions (including treatment of anonymous donations) to determine exclusion from total income.
Act Rules Income Tax
Show AI Summary
IFSC tax exclusion for specified financial incomes conditions relief on non-resident unit-holding, convertible receipts and prescribed rules.
Schedule VI excludes specified IFSC-related income from "total income" for defined eligible persons, listing discrete income heads (capital gains on IFSC exchange transfers, securities transfers, securitisation trust receipts, derivative and portfolio receipts, royalty/interest on aircraft/ship leases, specified fund returns, dividends of IFSC leasing units, and interest payable by IFSC units) together with conditional eligibility tied to convertible foreign exchange receipt, non-resident unit-holdings, commencement-of-operations windows, regulatory registration, and delegated computational prescriptions.
Act Rules Income Tax
Show AI Summary
Tax exclusion for institutional investment vehicles: conditional non inclusion of specified income subject to regulatory compliance and clawback.
Schedule V excludes specified income from total income for defined eligible persons-investment funds, business trusts (including REITs/InvITs), venture capital vehicles and certain foreign public investors-operating as a negative list subject to conditions and Notes. Exclusions include non business dividend and interest for investment funds, SPV interest/dividend exemptions for business trusts, REIT rental income exclusions for directly owned assets, and a layered specified person exemption with holding period, investment type, proportional computation, carve outs and clawback rules; implementation relies on cross references to SEBI/RBI/IFSC rules and Board guidelines.
Act Rules Income Tax
Show AI Summary
Non resident exemptions conditioned on residency, limited presence and Central Government notification restrict exclusions from taxable income.
Schedule IV excludes specified receipts from total income of defined non residents and foreign companies where each listed entry identifies the income class, eligible person and conditions for exclusion. Exclusions depend on factual predicates-residency under foreign exchange rules, limited period of presence, absence of employer taxable presence in India, RBI permissions for NR(E) accounts-and on Central Government notification or approved agreements. Key categories include NR(E) account interest, diplomatic remuneration, short term foreign employee remuneration, specified royalties/fees, Offshore Banking Unit deposits, intra group cruise lease rentals, regional community investments and notified crude oil arrangements.
Act Rules Income Tax
Show AI Summary
Income exclusions from total income: targeted, conditional exemptions rely on prescribed procedures and cross referenced regulations.
Schedule III excludes specified categories of receipts from total income for designated eligible persons, linking each excluded income to eligible person categories and conditional provisos. It covers personal reliefs (pensions, allowances, capped partial NPS withdrawals), partnership and family allocations, disaster compensation, conditional sectoral subsidies and institutional exemptions (research, khadi, securitisation, investor protection and settlement funds), and relies on prescribed procedures, certificates and cross references to subordinate legislation for operability.
Act Rules Income Tax
Show AI Summary
Life insurance exemption tightened by period, premium ratio and aggregate premium tests, altering tax treatment of policy and IFSC receipts.
Schedule II excludes specified classes of income from total income while imposing conditional tests on life insurance and retirement/savings receipts. Life insurance exclusions depend on policy issue periods, premium to sum assured ratios, aggregate premium ceilings and express ineligibility for certain receipts. Provident fund interest attributable to large post cut off contributions is excluded from exemption with the non excluded portion to be computed as prescribed. The Schedule adds an equalisation levy exclusion interacting with treaty notifications and treats IFSC issued policies differently under a targeted aggregate premium carve out.
Act Rules Income Tax
Show AI Summary
Business connection safe harbour for non-resident funds: compliance thresholds determine Indian tax nexus exclusion.
The Schedule establishes a safe harbour whereby certain non-resident investment funds and eligible fund managers will not constitute a business connection in India if they satisfy exhaustive investor-composition, concentration, corpus, independence, non-control, prohibited-associate-investment and arm's-length remuneration conditions, with specified carve-outs, transitional reliefs, registration requirements under prescribed securities-regulator frameworks, and filing and record keeping obligations to substantiate compliance.

TMI Notes

Back

All TMI Notes

Showing Results for :
Reset Filters
No Records Found

TMI Notes

Back

All TMI Notes

Comparison of section 511 "Furnishing of report in respect of international group." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

17 September, 2025

Contents
Acts
Rules & Regulations
Summary
Note

Note

-

Bookmark

Print

Print

Section 511 Furnishing of report in respect of international group

Income-tax Act, 2025

At a Glance

The document reproduces Clause 511 - Income Tax Bill, 2025 - Old Version, setting out reporting obligations for constituent entities of international groups (country-by-country reporting style). It matters for multinational groups with Indian resident constituent entities - both taxpayers (resident constituent entities, parent entities, alternate reporting entities) and the tax administration. Effective date or commencement is Not stated in the document.

Background & Scope

Statutory hooks: Clause 511 sits within miscellaneous provisions of the Income Tax Bill, 2025 and proposes a standalone reporting obligation for "international groups". The clause creates duties to notify the prescribed income-tax authority and to furnish reports containing consolidated and constituent-level financial and operational information. Definitions and scope are provided within the clause itself. Any subordinate rules, forms, timelines and thresholds are to be set out "as prescribed" (delegated rule-making).

Statutory Provision Mode

Text & Scope

Clause 511 imposes three principal obligations:

  • Notification (sub-section (1)): Every constituent entity resident in India that is part of an international group whose parent is not resident in India must notify the prescribed income-tax authority in the prescribed form and manner by the prescribed date whether it is the alternate reporting entity and/or provide details of the parent or alternate reporting entity and their jurisdictions.
  • Reporting (sub-section (2)): Every parent entity or alternate reporting entity resident in India must, for each reporting accounting year, furnish a report to the prescribed income-tax authority within twelve months from the end of that reporting accounting year, in the prescribed form and manner.
  • Fallback reporting (sub-section (4)): Where an Indian resident constituent entity is not the parent/alternate reporting entity, it must furnish the report within a prescribed period if the parent is resident in a jurisdiction that (a) is not obligated to file such a report; (b) lacks an agreement with India for exchange of the report; or (c) has experienced a "systemic failure" and that failure has been intimated by the prescribed income-tax authority.
  • Sub-sections (3) and (6) detail report content and exceptions; (7) grants the authority the power to issue notices and require supporting information; (8) provides a consolidated-revenue threshold exemption; and (9) permits application "as prescribed".

Interpretation

The text indicates a legislative intent to implement a country-by-country reporting regime targeted at large international groups with constituent entities resident in India. The use of express definitions (e.g., "consolidated financial statement", "parent entity", "constituent entity", "reporting accounting year") demonstrates an intent to align reporting obligations with financial reporting and with international standards for transfer pricing transparency. Several interpretive principles are signalled by the text: alignment with parent-jurisdiction financial periods, deference to prescribed forms and procedures, and reliance on intergovernmental agreements for automatic exchange.

Exceptions/Provisos

Key carve-outs and conditions:

  • Threshold exemption (sub-section (8)): The section will not apply if the total consolidated group revenue for the preceding accounting year does not exceed the prescribed amount - the specific monetary threshold is Not stated in the document.
  • Non-application where an alternate reporting entity files in its jurisdiction and certain conditions are met (sub-section (6)): Conditions include the foreign report being required by local law, presence of an exchange agreement between that country and India, absence of any systemic failure communicated by the Indian authority, written designation of the alternate reporting entity, and prior notification under sub-section (1). These are cumulative preconditions.
  • Fallback allocation where multiple Indian resident constituent entities exist (sub-section (5)): If more than one Indian constituent entity exists, any one designated entity may furnish the report provided the group has designated that entity and the information has been conveyed in writing to the prescribed authority.

Illustrations

  • Example 1: A multinational group with a non-resident parent and one Indian subsidiary that is designated as the alternate reporting entity must notify the income-tax authority in India and, if resident as alternate reporting entity, file the report within 12 months of the reporting accounting year end. (All procedural details - forms/timelines - are Not stated in the document.)
  • Example 2: An Indian permanent establishment (PE) of a foreign enterprise that prepares separate financial statements as a PE falls within "constituent entity" and, if the foreign parent's jurisdiction neither files nor exchanges reports with India, that Indian PE may be required to furnish the report within the prescribed period. (Precise prescribed period is Not stated in the document.)

Interplay

The clause expressly contemplates interaction with:

  • Section 159(1) or (2) (via the definition of "agreement") - signalling reliance on specified intergovernmental agreements for exchange.
  • Section 173(c) (for the meaning of "permanent establishment").
  • Prescribed rules/guidelines/conditions that remain to be issued for form, manner, dates and thresholds. The document does not reproduce any subordinate rules or forms. Specific interactions with existing transfer-pricing or information-exchange regimes are Not stated in the document beyond the express reference to agreements for exchange.

Differences between the Document 1 "Section 511 of Income-tax Act, 2025" and Document 2 "Clause 511 - Income Tax Bill, 2025 - Old Version"

  • Prescription wording: Document 1 repeatedly uses the phrase "as may be prescribed" (e.g., sub-sects (1), (2), (3), (9)), whereas Document 2 often uses the shorter "as prescribed".
    • Practical impact: negligible substantive difference in content; "as may be prescribed" can imply delegation to subordinate legislation, while "as prescribed" is more neutral - both indicate delegated rule-making. In practice, stakeholders should expect rules/guidelines to be issued regardless.
  • Minor phrasing differences: e.g., Document 1 in sub-section (4)(c) reads "where there has been a systemic failure of the country or territory and such failure has been intimated by the prescribed income-tax authority to such constituent entity" while Document 2 reads "where there has been a systemic failure and such failure has been intimated by the prescribed income-tax authority to such constituent entity."
    • Practical impact: none substantive; the enacted text in Document 1 clarifies that the systemic failure is of the foreign country/territory, but Document 2's meaning would be read the same way in context.
  • Overall: there are no material substantive differences in obligations, definitions, thresholds or exceptions between the two texts provided. The principal practical impact arises from the change in status from a Bill clause (Document 2) to an enacted statutory section (Document 1) and minor drafting refinements that preserve the same legal obligations and delegated-rulemaking expectation.

Practical Implications

  • Compliance and risk areas: Indian resident constituent entities of international groups must track whether their group's parent is resident outside India, determine whether they are designated as alternate reporting entity, and ensure timely notification to the prescribed income-tax authority. Parent or alternate reporting entities resident in India must prepare and file the prescribed report within 12 months of the reporting accounting year end. Failure to notify or file may expose entities to compliance actions under the Act and to information requests under sub-section (7).
  • Record-keeping/evidence: The text requires aggregated country-level financial and operational metrics and constituent-level details; accordingly, entities will need robust consolidated financial statements, country allocation methodologies, documentation of designation as alternate reporting entity, and written communications to the Indian authority. The precise content and format are "as prescribed" and therefore entities must monitor subordinate instruments for technical compliance requirements (not specified in the Bill text).

Key Takeaways

  • Clause 511 establishes country-by-country style reporting obligations for international groups with Indian resident constituent entities.
  • There is a dual duty: initial notification by Indian resident constituent entities (where parent is non-resident) and annual reporting by Indian parent/alternate reporting entities within 12 months of reporting accounting year end.
  • Fallback reporting obligations apply to Indian resident constituent entities if the parent's jurisdiction does not file, does not exchange, or has a communicated systemic failure.
  • Exemptions hinge on a consolidated revenue threshold for the preceding year; the specific threshold is to be prescribed and is Not stated in the document.
  • The power to request supporting information and documents within defined timelines is provided to the prescribed income-tax authority.
  • Many operational details (form, manner, prescribed dates, exact thresholds) are left to delegated rules; stakeholders must monitor rule-making for compliance specifics.

Full Text:

Section 511 Furnishing of report in respect of international group

Topics

Acts Income Tax