Income Tax : The Income Tax Act 2025 introduces mandatory reporting of high-value gifted immovable properties exceeding ₹45 lakh. The amendme...
Income Tax : Clause 43 in Tax Audit Form No. 26 requires auditors to verify remittances reported in Part-D of Form 145. Incorrect classificatio...
Income Tax : The new Income Tax Act, 2025 significantly reduces the number of statutory sections and reorganises tax compliance procedures effe...
Income Tax : The new law defines strict conditions for reopening assessments using specified information categories. It ensures transparency an...
Income Tax : The reform consolidates TDS provisions into a structured system and introduces digital compliance mechanisms. It enhances clarity,...
Income Tax : Rules 307–311 of the Draft Income-tax Rules, 2026 outline how pension funds must purchase annuities, restrict commutation, preve...
Income Tax : Draft Income-tax Rules 2026 prescribe definitions, trust conditions, investment rules, and limits on employer contributions for ap...
Income Tax : Draft Income-tax Rules 2026 outline procedures for provident fund recognition, penalties for assigning PF interest, and tax treatm...
Income Tax : Draft Income-tax Rules 2026 require provident fund nominations to favour family members and mandate annual account reporting by tr...
Income Tax : Rule 333 mandates electronic tax payments for companies and specified taxpayers, while the draft rules also prescribe detailed dep...
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 : CBDT introduced Income-tax Rules, 2026 to operationalize the Income-tax Act, 2025. The rules standardize procedures on valuation, ...
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.
Rule 111 of the Draft Income-tax Rules, 2026 permits rollback of Advance Pricing Agreements to earlier years subject to strict conditions, but disallows it where appellate orders exist or income is reduced.
Rule 110 of the Draft Income-tax Rules, 2026 clarifies that Advance Pricing Agreements are binding only if critical assumptions and conditions remain unchanged, and may be revised or cancelled upon material change.
Draft Rule 109 of the Income-tax Rules, 2026 lays down a detailed, time-bound procedure for processing Advance Pricing Agreement applications, including consultation, enquiry, agreement finalisation, and conditions for closure without refund.
Draft Rule 108 of the Income-tax Rules, 2026 establishes a structured deficiency review process for Advance Pricing Agreement applications, allowing correction of defects and providing for refund of fees if the application is rejected.
