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 proposed amendment to Rule 21B of the Special Economic Zones Rules, 2006 seeks to broaden the scope of activities allowed within International Financial Services Centres (IFSCs). Originally, Rule 21B permitted units in IFSCs to engage in aircraft leasing activities without the requirement of maintaining a separate office, provided it was approved by the International Financial Services Centre Authority. However, the proposed amendment replaces the term "aircraft leasing" with "aircraft or ship leasing," thereby expanding the types of leasing activities permitted within IFSCs to include both aircraft and ships.
The proposed amendment to Rule 21B of the Special Economic Zones Rules, 2006 seeks to broaden the scope of activities allowed within International Financial Services Centres (IFSCs). Originally, Rule 21B permitted units in IFSCs to engage in aircraft leasing activities without the requirement of maintaining a separate office, provided it was approved by the International Financial Services Centre Authority. However, the proposed amendment replaces the term "aircraft leasing" with "aircraft or ship leasing," thereby expanding the types of leasing activities permitted within IFSCs to include both aircraft and ships.
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