Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
AD Cat-I banks may exclude swap positions arising from FCNR (B) deposits, external commercial borrowings and overseas foreign currency borrowings raised under the specified swap-facility circulars, provided they continue to comply with A.P. (DIR Series) Circular No. 24 dated March 27, 2026. The circular operates as a clarification on the treatment of NOP-INR positions for these swap exposures and preserves compliance with other applicable legal requirements.
AD Cat-I banks may exclude swap positions arising from FCNR (B) deposits, external commercial borrowings and overseas foreign currency borrowings raised under the specified swap-facility circulars, provided they continue to comply with A.P. (DIR Series) Circular No. 24 dated March 27, 2026. The circular operates as a clarification on the treatment of NOP-INR positions for these swap exposures and preserves compliance with other applicable legal requirements.
Note: It is a system-generated summary and is for quick reference only.