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...
The FEMA (Non-debt Instruments) (Third Amendment) Rules, 2026 expand the relevant investment and transfer permissions from NRIs/OCIs to any individual person resident outside India, while retaining repatriation-based dealings in listed Indian companies and related securities. The amendment also revises Chapter V headings and Schedule III to align the framework with this broader category, subject to existing schedule conditions, Government approval for sensitive sectors, and additional approval where ownership or control would pass to entities or citizens of land-border countries or their beneficial owners. It also tightens portfolio holding limits, requires divestment or reclassification to FDI on breach of the ten per cent cap, and clarifies that interim breach is not a contravention if cured within the prescribed time.
The FEMA (Non-debt Instruments) (Third Amendment) Rules, 2026 expand the relevant investment and transfer permissions from NRIs/OCIs to any individual person resident outside India, while retaining repatriation-based dealings in listed Indian companies and related securities. The amendment also revises Chapter V headings and Schedule III to align the framework with this broader category, subject to existing schedule conditions, Government approval for sensitive sectors, and additional approval where ownership or control would pass to entities or citizens of land-border countries or their beneficial owners. It also tightens portfolio holding limits, requires divestment or reclassification to FDI on breach of the ten per cent cap, and clarifies that interim breach is not a contravention if cured within the prescribed time.
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