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TMI BlogSpecial Provision in respect of transaction with person located in Notified Jurisdictional Area - Section 94AX X X X Extracts X X X X X X X X Extracts X X X X ..... ormation 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 entered into by any assessee. Note - Clarification on removal of Cyprus from the list of notified jurisdictional areas under section 94A. [ Circular no. 15/2017 , dated 21.04.2017 ] If an Assessee enters into t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nclude a person who is a resident of NJA and a person not being an Individual, which is established in the NJA, it would also include a permanent establishment of any other person in NJA. Authorisation: Payments made to any financial institution located in NJA would not be allowed as deduction unless the assessee authorizes the CBDT or any other Income-Tax authority acting in behalf seeking releva ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ansmitted to the financial institution referred to in section 94A(3)(a) . (3) The second copy of the Form No.10FC along with the evidence of the first copy of said Form having been deposited or transmitted to the financial institution shall be submitted by the assessee to the Assessing Officer having jurisdiction over him (4) For the purpose of ensuring that the authorisation in Form No.10FC is le ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... directly more than ten per cent. shareholding or ownership interests; (b) a profile of the multinational group of which the specified person is a part along with the name, address, legal status and country of tax residence of each of the enterprises comprised in the group with whom the assessee has entered into a transaction, and ownership linkage among them; (c) a broad description of the busines ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the hands of the beneficial owner (if such person is not the beneficial owner of the said sum) or the explanation offered by the assessee, in the opinion of the AO, is not satisfactory, then, such sum shall be deemed to be the income of the assessee for that previous year. Rate of TDS: If any payment made to person located in NJA the TDS to be deducted from such payments at the rate or rates i ..... X X X X Extracts X X X X X X X X Extracts X X X X
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