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, ...
Rules 92–96 exclude safe harbour benefits for transactions with entities in notified or low-tax jurisdictions and deny MAP where safe harbour is accepted, while introducing domestic safe harbour relief for electricity and dairy co-operative transactions.
Rule 91 provides a five-year safe harbour regime for eligible IT service transactions with electronic verification, time-bound acceptance, and structured compliance requirements. The provision ensures transfer pricing certainty while restricting re-entry after withdrawal.
Rule 90 prescribes a structured filing process, TPO review mechanism, and strict timelines, ensuring that the safe harbour option becomes automatically valid if authorities fail to act within the stipulated period.
Rule 89 of the Draft Income-tax Rules, 2026 prescribes fixed profit margins, interest spreads, and transaction limits for eligible international transactions to secure automatic acceptance of transfer prices, reducing litigation and compliance uncertainty.
Draft Rule 88 of the Income-tax Rules, 2026 clearly identifies the categories of international transactions that qualify for safe harbour, helping taxpayers determine eligibility and reduce transfer pricing disputes.
Draft Rule 87 of the Income-tax Rules, 2026 specifies categories of eligible assessees and lays down stringent low-risk conditions to ensure certainty and simplified compliance under safe harbour transfer pricing rules.
Rules 85 and 86 of the Draft Income-tax Rules, 2026 mandate accountant certification for international and specified domestic transactions and define key terms for safe harbour rules. The provisions aim to standardize reporting timelines and clarify eligibility criteria for transfer pricing compliance.
Draft Rule 84 of the Income-tax Rules, 2026 requires taxpayers entering international or specified domestic transactions to maintain extensive contemporaneous documentation to substantiate arm’s length pricing and avoid disputes.
Draft Rule 83 of the Income-tax Rules, 2026 mandates a 90-day repatriation deadline for excess money arising from secondary transfer pricing adjustments, failing which imputed interest is levied at prescribed benchmark rates.
Rule 82 allows assessees to determine arm’s length price for two additional consecutive years in a single transfer pricing proceeding, provided strict similarity and compliance conditions are satisfied. The key takeaway: the option is available only where transactions, methods, and functional profiles remain materially unchanged.
