Income Tax : The Income-tax Act, 2025 replaces the dividend-based taxation of buy-backs with capital gains taxation for ordinary shareholders, ...
Income Tax : This guide explains when NRIs should use Form 128 and when payers should use Form 129 to reduce or eliminate excess TDS. It also c...
Income Tax : Sections 356-374 restructure appellate provisions with clearer drafting while retaining the existing appeal hierarchy and taxpayer...
Income Tax : Section 270 of the Income-tax Act, 2025 consolidates return processing and scrutiny assessment into one framework while introducin...
Income Tax : The law permits reassessment only where the Assessing Officer has information indicating escaped income and follows the prescribed...
Finance : The Government has exempted interest and capital gains earned by FPIs on Government securities from income tax with effect from 1 ...
Income Tax : A representation has urged CBDT to merge TDS return codes 1023 and 1024, arguing that both apply to the same contract payments wit...
Income Tax : Association requested CBDT to rationalize CASS 2026 case selection considering the administrative burden caused by implementation ...
Income Tax : The updated TDS challan system reportedly displays incorrect interest-related options under the Company Deductee category. Taxpaye...
Income Tax : The issue was complexity in the existing tax law. It was clarified that the new Act simplifies structure by reducing sections and ...
Income Tax : The Supreme Court set aside the NCLAT order for relying on a non-existent quasi-judicial income tax order. The key takeaway is tha...
Income Tax : Rule 81 prescribes dataset construction, weighted averages, and a 35th–65th percentile arm’s length range when multiple compar...
Income Tax : The latest amendment excludes income arising from transfer of pre-2017 investments from GAAR scrutiny. It reinforces the protectio...
Income Tax : The Finance Act, 2026 prescribes income-tax rates, surcharge, and cess for the assessment year 2026–27. It establishes the legal...
Income Tax : The circular introduces mandatory Form I and Form II for SWFs to claim tax exemptions. The ruling ensures structured application a...
Income Tax : The notification requires payers to generate UINs and file quarterly details of declarations even where no tax is deducted. It enh...
Income Tax : CBDT introduced Income-tax Rules, 2026 to operationalize the Income-tax Act, 2025. The rules standardize procedures on valuation, ...
Draft Rule 124 of the Income-tax Rules, 2026 sets out the procedure, timelines, and forms for furnishing country-by-country reports under section 511, triggered by a ₹6,400 crore consolidated revenue threshold.
Rule 122 of the Draft Income-tax Rules, 2026 requires the foreign associated enterprise to initiate an APA process before India begins bilateral or multilateral negotiations, ensuring coordinated and mutually acceptable transfer pricing agreements.
Draft Rule 123 of the Income-tax Rules, 2026 requires constituent entities of large international groups to maintain and furnish extensive documentation when revenue and transaction thresholds are exceeded.
Rule 121 of the Draft Income-tax Rules, 2026 lays down a structured mutual agreement procedure with defined timelines and safeguards, ensuring transparent resolution of cross-border tax disputes without reducing declared income in India.
Rule 118 introduces a structured computation mechanism to reduce tax payable when past income from APA or secondary adjustments is included in book profits, ensuring no excess tax burden while adjusting tax credit accordingly.
Rules 119 and 120 clarify renewal of agreements via fresh Form 54 application and confirm Chapter X applies until execution, with treaty-based negotiation for bilateral deals.
Rule 114 of the Draft Income-tax Rules, 2026 requires the Transfer Pricing Officer to conduct annual compliance audits of APAs, ensuring adherence to agreed terms and critical assumptions.
Rule 117 requires filing of modified returns, payment of additional tax, and withdrawal of pending appeals to give effect to rollback provisions, failing which the agreement may be cancelled.
Rules 112 and 113 of the Draft Income-tax Rules, 2026 allow amendment of APA applications before finalisation and mandate timely filing of annual compliance reports to ensure continued adherence.
Rules 115 and 116 empower the Board to revise or cancel agreements where conditions fail, laws change, or compliance lapses occur, while mandating hearings, written reasons, and procedural safeguards to ensure transparency.
