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...
SEBI has amended AIF Regulations to allow Category I and II AIFs to create encumbrances on equity holdings in investee companies for debt raising. Encumbrances without disclosure must obtain investor consent by Oct 24, 2024, or be removed by Jan 24, 2025. Borrowings against encumbered equity must be used for investee company purposes only. Duration of encumbrance cannot exceed scheme tenure. AIFs with foreign investments must comply with RBI guidelines. AIFs must not be liable beyond encumbered equity in case of borrower default. Encumbrance does not permit guarantee extension. No encumbrances on foreign investments. SFA will set implementation standards for infrastructure sector debt raising. Compliance Test Report must include adherence to circular. Circular effective immediately u/s 11(1) of SEBI Act to protect investor interests and regulate securities market.
SEBI has amended AIF Regulations to allow Category I and II AIFs to create encumbrances on equity holdings in investee companies for debt raising. Encumbrances without disclosure must obtain investor consent by Oct 24, 2024, or be removed by Jan 24, 2025. Borrowings against encumbered equity must be used for investee company purposes only. Duration of encumbrance cannot exceed scheme tenure. AIFs with foreign investments must comply with RBI guidelines. AIFs must not be liable beyond encumbered equity in case of borrower default. Encumbrance does not permit guarantee extension. No encumbrances on foreign investments. SFA will set implementation standards for infrastructure sector debt raising. Compliance Test Report must include adherence to circular. Circular effective immediately u/s 11(1) of SEBI Act to protect investor interests and regulate securities market.
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