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SPECIAL MEASURES IN RESPECT OF TRANSACTIONS WITH PERSONS LOCATED IN NOTIFIED JURISDICTIONAL AREA - SECTION 94A

SPECIAL MEASURES IN RESPECT OF TRANSACTIONS WITH PERSONS LOCATED IN NOTIFIED JURISDICTIONAL AREA - SECTION 94A - Income Tax - Tax Liability in special Circumstances / Specific Cases - 20 - SPECIAL MEASURES IN RESPECT OF TRANSACTIONS WITH PERSONS LOCA .....

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on in the Official Gazette such country or territory as a notified jurisdictional area in relation to transactions entered into by any assessee. APPLICABILITY OF TRANSFER PRICING PROVISIONS [Sec.94A(2)] If an assessee enters into a transaction, where .....

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on within the meaning of section 92B, and the provisions of sections 92, 92A, 92B, 92C [except the second proviso to sub-section (2)], 92CA, 92CB, 92D, 92E and 92F shall apply accordingly. CONSEQUENCES If the aforesaid pre-conditions are fulfilled: T .....

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ation between actual transaction price and ALP is less than 5% of actual transaction price; ALP shall be taken). Deduction of interest [Section 94A(3)(a)]:- Any payment made to any financial institution located in an NJA shall be allowed as a deducti .....

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owed on the basis of Arm s Length Price. Deduction of Expenses and Depreciation [Section 94A(3)(b)]: No deduction in respect of any other expenditure or allowance (including depreciation) arising from the transaction with a person located in an NJA s .....

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see has received or credited any sum from any person located in a notified jurisdictional area and the assessee does not offer any explanation about the source of the said sum in the hands of such person or in the hands of the beneficial owner (if su .....

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