Friday , July 18, 2025 |   23:06:05 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Newsletters
 
NEWS FLASH
 
I-T- Compulsorily Convertible Debentures & Optionally Convertible Debentures, until conversion, retain essential characteristics of debt instruments akin to NCDs; ergo, qualify as debentures or bonds for tax purposes: ITAT (See Breaking News) TP - Separate adjustment for receivables results in duplication, if economic effect of extended credit period is already subsumed in working capital adjustment: ITAT (See Breaking News) I-T -Payments received by assessee will be business profits rather than royalty, where assessee merely organizes publicly available scientific information in a database & provides access to it, without transferring any copyright or proprietary rights to customers: ITAT (See Breaking News) TP - TPO's approach in insisting upon daily/monthly working capital cycle data of third-party comparable is, unjustified if such data is admittedly not available in public domain: ITAT (See Breaking News) TP- TNMM operates at net margin level & tolerates transactional differences; hence pricing mechanism or revenue scale alone cannot justify rejection of internal TNMM: ITAT (See Breaking News) INTL - As is trite law, filing of Form 67 is directory and not mandatory; delay in filing Form 67 should not lead to disallowance of Foreign Tax Credit: ITAT (See Breaking News) TP - Reference which was made to TPO after date when clause (i) of section 92BA was omitted by Finance Act, 2017, is not sustainable: ITAT (See Breaking News) I-T - Reimbursement of salary paid to AEs which are merely in nature of reimbursements of seconded employee and does not include any element of income, does not attract TDS: ITAT (See Breaking News) I-T - Final assessment order passed by AO merits to be quashed if it is not in conformity with DRP directions: ITAT (See Breaking News) I-T - If allocation/attribution of income to PE is at arm's length, then no further ad-hoc attribution is required: ITAT (See Breaking News) TP - While principle of res judicata does not apply to tax proceedings, the principle of consistency must be observed, especially where there is no change in facts or legal position: ITAT (See Breaking News) TP - Provision for bad & doubtful debts is only accounting treatment and have no direct nexus to operating income: ITAT (See Breaking News) TP - Working capital adjustment can't be denied merely due to absence of detailed working capital cycle data and adjustment should be granted based on average of opening & closing balances: ITAT (See Breaking News) DTAA - Prior taxability of similar income in earlier years does not bar assessee's lawful claim for relief in current year, more so when there is no change in facts: ITAT (See Breaking News) Netherlands to grow at 1.3% rate in 2025: OECD (See Brief) TP - Corporate guarantee given by assessee on behalf of AE in absence of any expenditure being incurred by assessee, would not constitute international transaction within meaning of Sec 92B: ITAT (See Breaking News) TP - Gross profitability margin may vary significantly over time, and hence, reliance on data of earlier years would not constitute reliable benchmark: ITAT (See Breaking News) DTAA - Management support services do not make available any technical knowledge or skill to recipient; ergo, consideration therefor is not taxable as FTS under India-Singapore DTAA: ITAT (See Breaking News) I-T - Amortization of capital subsidy in itself is not allowable as direct deduction u/s 80-IC, rather impact of capital subsidy is reflected in reduced "actual cost" of asset, leading to claim of lower depreciation: ITAT (See Breaking News) I-T - If repair & maintenance of aircraft equipment provided by foreign assessee to Indian airline operators, did not involve transfer of technology, then receipts from said services are not taxable as FIS: HC (See Breaking News) TP - If number of transactions are closely linked, then same should be treated as composite transaction and can be aggregated and construed as single transaction for purpose of determining ALP: ITAT (See Breaking News)
 
TII SEARCH
 
 
   
Home >>
 

Vivad Se Vishwas Scheme - Order to remove difficulty issued
By TII News Service
Jan 20, 2025 , New Delhi

    
Untitled Document

GOVERNMENT OF INDIA
MINISTRY OF FINANCE
DEPARTMENT OF REVENUE
CENTRAL BOARD OF DIRECT TAXES
NEW DELHI

NOTIFICATION NO

08/2025; Dated: January 20, 2025

S.O. 348(E) - WHEREAS, the Direct Tax Vivad Se Vishwas Scheme, 2024 was introduced vide the Finance (No.2) Act, 2024 (15 of 2024) and came into force with effect from the 1st day of October, 2024; WHEREAS, while implementing the said Scheme difficulties have arisen in situations where,––

(a) an order in case of a person had been passed on or before the specified date i.e. the 22nd day of July, 2024;

(b) the time for filing an appeal in respect of such order was available as on the said date;

(c) appeal in respect of such order was filed after the said date within the stipulated time as applicable for filing of such appeal; and

(d) aforesaid appeal is filed without any application for condonation of delay;

WHEREAS, section 98 of the said Finance (No.2) Act, 2024 provides that if any difficulty arises in giving effect to the provisions of the Scheme, the Central Government may, by Order, not inconsistent with the provisions of the Scheme, remove the difficulty;

NOW THEREFORE, in exercise of the powers conferred by sub-section (1) of section 98 of the Finance (No.2) Act, 2024, the Central Government hereby makes the following Order to remove the difficulty, namely:––

(i) in the case of such a person, aforesaid appeal shall be considered as pending as on the 22nd day of July, 2024 for the purposes of the said Scheme;

(ii) such a person shall be considered as an appellant for the purposes of the said Scheme;

(iii) in such a case, disputed tax shall be calculated on the basis of such appeal; and

(iv) the provisions of the said Scheme and the rules framed thereunder shall apply accordingly in such a case.

[F. No. 370153/01/2025-TPL]

(Pradeep Sharma)
Dy. Secy., Tax Policy & Legislative Division

 
 
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI TII
  • DTAA
  • Circulars (I-T Act, 1922)
  • Limited Treaties
  • Other Treaties
  • TIEAs
  • Notifications
  • Circulars
  • Relevant Sections of I-T Rules,1962
  • Instructions
  • Administrative Orders
  • DRP Panel
  • I-T Act, 1961
  • MLI
  • Relevant Portion of I-T Act,1922
  • GAAR
  • MAP
  • OECD Conventions
  • Draft Guidelines
  • DTC Bill
  • Committee Reports
  • FATCA
  • Intl-Taxation
  • Finance Acts
  • Manual on EoI
  • UN Model Taxation
  • Miscellaneous
  • Cost Inflation Index
  • Union Budget
  • Information Security Guidelines
  • APA Annual Report
  • APA Rules
  • Miscellaneous
  • Relevant Sections of Act
  • Instructions
  • Circulars
  • Notifications
  • Draft Notifications
  • Forms
  • TP Rules
  • APA FAQ
  • UN Manual on TP
  • Safe Harbour Rules
  • US Transfer Pricing
  • FEMA Act
  • Exchange Manual
  • Fema Notifications
  • Master Circulars
  • Press Notes
  • Rules
  • FDI Circulars
  • RBI Circulars
  • Reports
  • FDI Approved
  • RBI Other Notifications
  • FIPB Review
  • FEO Act
  • INTELLECTUAL PROPERTY
  • CBR Act
  • NBFC Report
  • Black Money Act
  • PMLA Instruction
  • PMLA Bill
  • FM Budget Speeches
  • Multimodal Transportation
  • Vienna Convention
  • EXIM Bank LoC
  • Manufacturing Policy
  • FTDR Act, 1992
  • White Paper on Black Money
  • Posting Policy
  • PMLA Cases
  • Transfer of Property
  • MCA Circular
  • Limitation Act
  • Type of Visa
  • SSAs
  • EPFO
  • Acts
  • FAQs
  • Rules
  • Guidelines
  • Tourist Visa
  • Notifications
  • Arbitration
  • Model Text
  • Agreements
  • Relevant Portion of I-T Act
  • I-T Rules, 1962
  • Circulars
  • MISC
  • Notification
  • About Us
  • Contact Us
  •  
     
    A Taxindiaonline Website. Copyright © 2010-2025 | Privacy Policy | Taxindiainternational.com Pvt. Ltd. OPC All rights reserved.