Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Delayed trade receivables from associated enterprises are treated as a separate international transaction where realisation exceeds the normal credit period and provides an uncompensated financing benefit. Acceptance of the underlying IT/SDS service margin at arm's length, or inclusion of finance costs in operating costs, does not itself establish arm's-length compensation for extended credit. A debt-free service provider with no interest-bearing borrowings may not require a notional interest adjustment, subject to factual verification. For foreign-currency IT/SDS receivables, the article notes benchmarking at LIBOR plus 200 basis points after allowing a 60-day credit period.
Delayed trade receivables from associated enterprises are treated as a separate international transaction where realisation exceeds the normal credit period and provides an uncompensated financing benefit. Acceptance of the underlying IT/SDS service margin at arm's length, or inclusion of finance costs in operating costs, does not itself establish arm's-length compensation for extended credit. A debt-free service provider with no interest-bearing borrowings may not require a notional interest adjustment, subject to factual verification. For foreign-currency IT/SDS receivables, the article notes benchmarking at LIBOR plus 200 basis points after allowing a 60-day credit period.
Note: It is a system-generated summary and is for quick reference only.
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