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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Social Protection Fund is specified as an eligible pension fund for tax exemption on qualifying investments made in India from publication of the notification until 31 March 2030. Exemption requires timely income-tax returns with an accountant's compliance certificate, quarterly investment disclosures, and separate accounts for exempt investments. The fund must remain regulated under Omani law, use assets and earnings solely for statutory and defined-benefit obligations, avoid India-investment borrowings, and not participate in investees' day-to-day operations, subject to permitted investment-protection monitoring. Breach of any prescribed condition makes the fund ineligible for the exemption. The notification takes effect upon Gazette publication.
Social Protection Fund is specified as an eligible pension fund for tax exemption on qualifying investments made in India from publication of the notification until 31 March 2030. Exemption requires timely income-tax returns with an accountant's compliance certificate, quarterly investment disclosures, and separate accounts for exempt investments. The fund must remain regulated under Omani law, use assets and earnings solely for statutory and defined-benefit obligations, avoid India-investment borrowings, and not participate in investees' day-to-day operations, subject to permitted investment-protection monitoring. Breach of any prescribed condition makes the fund ineligible for the exemption. The notification takes effect upon Gazette publication.
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