There is a peculiar history regarding the amendments of section 90 of the Income-Tax Act, 1961 (the Act), by the Finance Act, 2012 and the Finance Act, 2013, in respect of the requirement of Tax Residency Certificate (TRC) to be obtained by an assessee, in order to avail of the benefit of Double Taxation Avoidance Agreement (DTAA) between India and the country of his residence.
Attention is invited to Board’s Circular No 22/2012-Cus dated 07.08.2012, whereby 24X7 Customs clearance was made operational on pilot basis with effect from 01.09.2012 at identified Air Cargo Complexes and Sea ports for following item of imports/exports:-
The matter has been examined by us in consultation with Indian Banks’ Association (IBA). With a view to protect interest of the depositors and for rendering better customer service, banks are advised to give an acknowledgment at the time of receipt of Form 15-G/15-H. This will help in building a system of accountability and customers will not be put to inconvenience due to any omission on part of the banks.
In exercise of the powers conferred by sub-section (2) of section 14 of the Customs Act, 1962 (52 of 1962), the Central Board of Excise & Customs, being satisfied that it is necessary and expedient so to do, hereby makes the following amendment in the
Notification No. 39/2013 – Income Tax Notwithstanding anything contained in sub-rule (1) or sub-rule (2), any sum deducted under section 194-IA shall be paid to the credit of the Central Government within a period of seven days from the end of the month in which the deduction is made and shall be accompanied by a challan-cum-statement in Form No.26QB
In our opinion, the amount representing 2118.84 is towards investment in share capital of the subsidiaries outside India as the transactions are not in the nature of transactions referred to section 92-B of the IT Act and the transfer pricing provisions are not applicable as there is no income.
This notification substitutes the updated versions of UN and IAEA documents, namely, INFCIRC/254/Rev.11/Part 1 and INFCIRC/254/Rev.8/Part 2 (IAEA documents), S/2012/947, S/2009/364 and S/2006/853 (UN Security Council documents) and Annex III to UN Security Council resolution 2094 (2013) for the existing documents mentioned in Para 2.1.2 of FTP.
Once the CBDT has issued instructions for assumption of jurisdiction for selection of cases of corporate assesses for scrutiny and assessment thereof, the same have to be followed in letter and spirit by the AO .
Whether A Person Can Refuse To Provide Information Relating To Its ‘Personal’ Income Tax Returns, Financial Statements Etc., If Such Information Is To Be Provided To A Government Body In The Course Of Application For Certain Licenses, Permits, Grants Etc.
Consequent to the amendment in Section 129C(4) of the Customs Act 1962, Section 350(3) of the Central Excise Act 1944 and corresponding changes in provisions of the Finance Act 1994 by virtue of Section 86(7) thereof, the Single Member Jurisdiction stands enhanced to Rs. 50 Lacs.