Limitation on interest deduction in certain cases (1) Notwithstanding anything contained in this Act, where an Indian company, or a permanent establishment of a foreign company in India, being the borrower, incurs any expenditure by way of interest or of similar nature exceeding one crore rupees which is deductible in computing income chargeable under the […]

Special measures in respect of transactions with persons located in notified jurisdictional area (1) The Central Government may, having regard to the lack of effective exchange of information with any country or territory outside India, specify by notification in the Official Gazette such country or territory as a notified jurisdictional area in relation to transactions

Avoidance of tax by certain transactions in securities  (1) Where the owner of any securities (in this sub-section and in sub-section (2) referred to as “the owner”) sells or transfers those securities, and buys back or reacquires the securities, then, if the result of the transaction is that any interest becoming payable in respect of

Avoidance of income-tax by transactions resulting in transfer of income to non-residents (1) Where there is a transfer of assets by virtue or in consequence whereof, either alone or in conjunction with associated operations, any income becomes payable to a non-resident, the following provisions shall apply— (a) where any person has, by means of any

Definitions of certain terms relevant to computation of arm’s length price, etc  In sections 92, 92A, 92B, 92C, 92D and 92E, unless the context otherwise requires,—   (i) “accountant” shall have the same meaning as in the Explanation below sub-section (2) of section 288;  (ii) “arm’s length price” means a price which is applied or proposed to be applied in a transaction between persons other

Report from an accountant to be furnished by persons entering into international transaction or specified domestic transaction Every person who has entered into an international transaction or specified domestic transaction during a previous year shall obtain a report from an accountant and furnish such report on or before the specified date in the prescribed form

Maintenance, keeping and furnishing of information and document by certain persons (1) Every person,— (i) who has entered into an international transaction or specified domestic transaction shall keep and maintain such information and document in respect thereof as may be prescribed43; (ii) being a constituent entity of an international group, shall keep and maintain such

Secondary adjustment in certain cases (1) Where a primary adjustment to transfer price,—  (i) has been made suo motu by the assessee in his return of income; (ii) made by the Assessing Officer has been accepted by the assessee; (iii) is determined by an advance pricing agreement entered into by the assessee under section 92CC, on or after

Effect to advance pricing agreement  (1) Notwithstanding anything to the contrary contained in section 139, where any person has entered into an agreement and prior to the date of entering into the agreement, any return of income has been furnished under the provisions of section 139 for any assessment year relevant to a previous year to which such

Advance pricing agreement (1) The Board, with the approval of the Central Government, may enter into an advance pricing agreement with any person, determining the— (a) arm’s length price or specifying the manner in which the arm’s length price is to be determined, in relation to an international transaction to be entered into by that