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...
SEBI's Master Circular consolidates the circulars applicable to Alternative Investment Funds under the AIF Regulations, incorporating provisions issued up to May 31, 2026 and superseding the Master Circular dated May 07, 2024. The circulars listed in Annexure 21 are rescinded to the extent they relate to AIFs, while prior actions, pending applications, and accrued rights, liabilities, penalties, investigations and remedies under the rescinded circulars continue as if those circulars remained in force. Trustees, sponsors or managers must ensure that the Compliance Test Report under para 21.2 covers compliance with all chapters of the Master Circular.
SEBI's Master Circular consolidates the circulars applicable to Alternative Investment Funds under the AIF Regulations, incorporating provisions issued up to May 31, 2026 and superseding the Master Circular dated May 07, 2024. The circulars listed in Annexure 21 are rescinded to the extent they relate to AIFs, while prior actions, pending applications, and accrued rights, liabilities, penalties, investigations and remedies under the rescinded circulars continue as if those circulars remained in force. Trustees, sponsors or managers must ensure that the Compliance Test Report under para 21.2 covers compliance with all chapters of the Master Circular.
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