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...
InvITs may add back, in calculating net distributable cash flows at both HoldCo/SPV and Trust levels, payments for major maintenance of road projects funded by external borrowings. This exception to the general prohibition on debt-funded cash distributions requires prior unitholder approval for each relevant project, including approval for additional borrowing beyond an approved proposal. Major maintenance must be non-routine expenditure required by the concession agreement. Statutory auditor certification, specified disclosures on borrowing, debt maturity, NDCF and distribution impacts, and disclosures of funding alternatives are required. The revised framework takes effect immediately.
InvITs may add back, in calculating net distributable cash flows at both HoldCo/SPV and Trust levels, payments for major maintenance of road projects funded by external borrowings. This exception to the general prohibition on debt-funded cash distributions requires prior unitholder approval for each relevant project, including approval for additional borrowing beyond an approved proposal. Major maintenance must be non-routine expenditure required by the concession agreement. Statutory auditor certification, specified disclosures on borrowing, debt maturity, NDCF and distribution impacts, and disclosures of funding alternatives are required. The revised framework takes effect immediately.
Note: It is a system-generated summary and is for quick reference only.
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