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Draft Income Tax Rule 129 – Notice, Forms for reference under section 274

February 28, 2026 807 Views 0 comment Print

Rule 129 prescribes notice and forms for Section 274 reference, detailing objections, tax benefit basis, and Commissioner’s satisfaction before invoking Chapter XI provisions.

Draft Income Tax Rule 127and 128: Tax Consequences of Impermissible Avoidance Arrangements; GAAR (Chapter XI) Inapplicable in Specified Cases

February 28, 2026 390 Views 0 comment Print

Rules 127 and 128 of the Draft Income-tax Rules, 2026 restrict GAAR impact to the tainted part of an arrangement and exempt cases below ₹3 crore tax benefit and specified FII investments.

Draft Income Tax Rule 126 – Conditions and activities for the Finance Company located in any International Financial Services Centre for section 177

February 28, 2026 291 Views 0 comment Print

Draft Rule 126 of the Income-tax Rules, 2026 limits eligible activities of IFSC-based Finance Companies and mandates foreign currency interest payments to qualify under section 177.

Draft Income Tax Rule 125 – Furnishing of authorization and maintenance of documents, etc. for the purposes of section 176

February 28, 2026 435 Views 0 comment Print

Draft Rule 125 of the Income-tax Rules, 2026 mandates Form 61 authorization filing and extensive ownership disclosures for transactions with notified jurisdictional areas, requiring eight-year record retention to strengthen compliance.

Draft Income Tax Rule 124 – Furnishing of report in respect of an international group under section 511

February 28, 2026 603 Views 0 comment Print

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.

Draft Income Tax Rule 122 – Procedure to deal with requests for bilateral or multilateral advance pricing agreements

February 28, 2026 300 Views 0 comment Print

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 Income Tax Rule 123 – Maintenance and Furnishing of Information by Constituent Entity under Section 171

February 28, 2026 282 Views 0 comment Print

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.

Draft Income Tax Rule 121 – Application and Procedure to Give Effect to Agreement under Section 533(2)(p)

February 28, 2026 4857 Views 0 comment Print

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.

Draft Income Tax Rule 118 – Relief in tax payable under section 206(1) due to operation of section 206(1)(i)

February 28, 2026 432 Views 0 comment Print

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.

Draft Income Tax Rules 119 and 120 – Renewal of Agreement and Miscellaneous Provisions

February 28, 2026 252 Views 0 comment Print

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.

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