Monday , December 29, 2025 |   19:43:37 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Newsletters
 
NEWS FLASH
 
DTAA - Once it is shown that leased aircraft formed part of fleet used on both domestic and international sectors, rental income falls within protective ambit of Article 8(1) of Indo-Ireland Treaty: ITAT (See Breaking News) I-T - Routine repairs do not constitute 'FTS' as they are not technical services, and payments for these services alone does not attract Sec 9(1)(vii), and not liable to tax at source u/s 195: ITAT (See Breaking News) DTAA - Assessee cannot avail benefit under India-Cyprus DTAA, where Assessee is not found to be beneficial owner of income in question: ITAT (See Breaking News) I-T - CIT(A) must provide proper & adequate opportunity of hearing to assessee, who shall substantiate its case with all relevant paper books and documents without delay: ITAT (See Breaking News) I-T - Taxpayer has right to rely on treaty provisions and question of touching brought forward capital losses does not arise in subsequent AYs once eligibility to carry these losses forward was determined in year they were suffered: ITAT (See Breaking News) TP - Mere failure to satisfy need/purpose/benefit/rendition test alone is no basis to disallow intra group services between AEs: ITAT (See Breaking News) Treaty-shopping: Nepal ejects Mauritius out of its cart (See TII Edit) TP - Resale price method is most appropriate for benchmarking international transaction in its distribution segment: ITAT (See Breaking News) TP - CIT(A) ought not to have restored matter back to AO under mistaken view that it was ex-parte order: ITAT (See Breaking News) I-T - 'Test of imparting' is touchstone if foreign entity continues to use its own industrial and commercial experience to render services, and essence of royalty lies in alienation, not in application: ITAT (See Breaking News) I-T - Reimbursements of expenses made on cost to cost basis, i.e. without any markup, cannot be treated as FIS, in absence of make available clause: ITAT (See Breaking News) I-T - No attribution of profit can be made to PE when there is no existence of PE at all: ITAT (See Breaking News) I-T - Payments made for providing standard facility for data processing without any human intervention, is not taxable in India as FTS in terms of Sec 9(1)(vii): ITAT (See Breaking News) I-T - Receipts from distribution activity is not royalty in absence of dependent agent PE: ITAT (See Breaking News) TP - If there was no value addition, and assessee only sought reimbursement of expenses on cost to cost basis, no ALP adjustment is permitted on account of same: ITAT (See Breaking News) DTAA - Concepts like virtual PE or Significant Economic Presence, while reflecting evolving international taxation trends, cannot be judicially read into a DTAA, absent express amendment: HC (See Breaking News) DTAA - OECD materials and practices of other jurisdictions are not relevant against clear language in relevant DTAA: HC (See Breaking News) I-T - Mismatches in limbs of provisions of section 271(1)(c) renders levy of penalty invalid: 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.